dissenting opinion.
Steve and Anita Ritchie brought a claim under their Allied insurance policy for the death of their daughter. She was a passenger in a car driven by Noah Heath that collided with a car driven by Adam Tom-blin. Although the Richies obtained a judgment against Mr. Heath and Mr. Tom-blin in the amount of $1.8 million, they only recovered $60,000 because both were underinsured. Accordingly, the Ritchies brought a claim against their insurer Allied for underinsured motorist coverage (UIM). The Ritchies had one policy from Allied that covered each of their three vehicles with a maximum $100,000 of liability for injuries per person. Their policy also had an anti-stacking provision and a limit of liability provision that read:
*142A. The limit of liability shown in the Declarations for each person for Under-insured Motorists coverage is our maximum limit of liability for all damages for case, loss of services, or death arising out of “bodily injury” sustained by any one person in any one accident ... This is the most we will pay regardless of the numbers of:
1. “Insureds;”
2. Claims made;
3. Vehicles or premiums shown in the Declarations;
or
4. Vehicles involved in the accident.
B. The limit of liability shall be reduced by all sums: ... [pjaid because of ‘bodily injury’ or by or on behalf of persons organizations who may be legally responsible ...
The majority refuses to give effect to these provisions for two reasons. First, they argue that they conflict with the “other insurance” excess clause in the policy which reads:
Any coverage we provide with respect to a vehicle you do not own shall be excess over any other collectible un-derinsured motorist coverage.
Second, the majority takes issue with the limit of liability language of the policy, arguing that because the UIM policy will never pay out its absolute limit, it is misleading and ambiguous. I disagree with both points. The majority creates ambiguities where none naturally arise. I would enforce the anti-stacking and limit of liability provisions.
I. Ambiguities in Insurance Contracts
An ambiguity arises when there is duplicity, indistinctness or uncertainty in the meaning of the words used in the contract. Nixon v. Life Investors Insurance Co., 675 S.W.2d 676, 679 (Mo.App.1984). When interpreting that agreement, a court cannot create an ambiguity where none exists to enforce a particular construction that it might feel is more appropriate. Rodriguez v. Gen. Acc. Ins. Co. of Am., 808 S.W.2d 379, 382 (Mo. banc.1991). Where insurance policies are unambiguous, they will be enforced as written absent a statute or public policy requiring coverage. Hempen v. State Farm Mutual Automobile Insurance Co., 687 S.W.2d 894, 894 (Mo. banc 1985).
II. The Anti-Stacking and “Other Insurance” Clauses Do Not Conflict and Do Not Create an Ambiguity
An anti-stacking clause and an “other insurance” clause are two distinct insurance policy provisions that address different subject matters.
An anti-stacking clause prohibits the insured from collecting on multiple coverage items or policies from the same insurer for a single accident. In effect, it makes only one policy or coverage amount collectable. See Noll v. Shelter Ins. Companies, 774 S.W.2d 147 (Mo.1989); see also Couch on Insurance, § 169:4 (3d. ed. 2005). An anti-stacking clause will be upheld if it is unambiguous. Rodriguez v. General Acc. Ins. Co. of America, 808 S.W.2d 379, 383 (Mo. banc 1991). This Court already upheld essentially the same anti-stacking clause as Allied’s as unambiguous and enforceable as a matter of law in Rodnguez, 808 S.W.2d at 381.1
*143“Other insurance” provisions are different in subject matter, but also are enforced as written under Missouri law. Distler v. Reuther Jeep Eagle, 14 S.W.3d 179,183 (Mo.App.2000); MFA Mwt. Ins. v. American Family Mut. Ins., 654 S.W.2d 230, 233 (Mo.App.1983). They address situations in which different insurers have issued policies that cover the same event. Planet Ins. Co. v. Ertz, 920 S.W.2d 591, 593 (Mo.App.1996) (“ ‘Other insurance’ clauses are provisions inserted in insurance policies to vary or limit the insurer’s liability when additional, concurrent insurance exists to cover the same loss.”)
The type of “other insurance” clause here is an excess clause that makes the policy “payable after other policies.” Id. Historically when our courts have addressed the operation of “other insurance,” it was to resolve conflicts between multiple insurers over which insurer must pay in what order.2
Only recently, in Seeck v. Geico General Ins. Co., 212 S.W.3d 129 (Mo. banc 2007), has this Court turned these outward-looking provisions inward toward the internal operation of a single policy’s language.3 This approach misconstrues how courts, insurance carriers and insureds have traditionally interpreted “other insurance” provisions to apply.
The use of an “other insurance” clause and an anti-stacking clause in a policy is neither conflicting nor ambiguous. “ ‘Other insurance’ clauses address rules for determining responsibility if more than one coverage is considered to apply, while stacking addresses whether more than one coverage which would otherwise be applicable should, in fact, he applied at all.” Couch on Insurance, § 169:9 (3d. ed. 2005) [emphasis added]. As other jurisdictions have noted, “other insurance” clauses are “entirely unilluminating in deciding the question of whether more than one policy applies.” Goetz v. American Reliable Ins. Co., 844 P.2d 366, 370 (Utah App.1992); Mississippi Farm Bureau Cas. Ins. Co. v. Britt, 826 So.2d 1261, 1264 (Miss.2002). This is the question reached by the anti-stacking clause.
Here, Allied’s anti-stacking clause applied. Although the Ritchies’ policy covered these vehicles, it allowed recovery of only one limit. Because there were no “other collectible underinsurance policies,” the “other insurance” clause was not triggered. There is no conflict between these two provisions, and both can plainly be read together. This Court should enforce them as written.
III. The Limit of Liability Provision is Enforceable
The majority also argues that because “Allied will never in fact pay out the full amount” of the policy limit, the contract purports to give something (the $100,000 limit) and then take it away (with a set-*144off), which creates an ambiguity. The Eighth Circuit made the same argument when interpreting a Missouri UIM insurance contract in Weber v. American Family Mutual Insurance Co., 868 F.2d 286, 288 (8th Cir.1989). The policy in Weber provided for a maximum $50,000 payout for bodily injuries sustained in an accident. Id. Then, the liability insurance of the underinsured tortfeasor was deducted from that amount. Id. The Eighth Circuit argued that:
[I]f the tortfeasor’s insurer paid $25,000, then the insured would be paid $25,000 on her underinsured motorist coverage; and if the tortfeasor’s insurer paid one dollar then the insured would receive $49,999 from her own coverage. Never could the insured recover the full $50,000 in underinsured motorist benefits ... [which] rendered the coverage meaningless. Rodriguez v. General Acc. Ins. Co. of America, 808 S.W.2d 379, 383 (Mo.1991) (summarizing Weber, 868 F.2d at 288)
This Court explicitly rejected Weber in Rodriguez, saying that this analysis was “inconsistent with Missouri law” and “an example of a court creating an ambiguity in order to distort the language of an unambiguous policy.” Rodriguez, 808 S.W.2d at 383 (Mo.1991). An underinsurance policy is not illusory or ambiguous because of “mathematical inability to collect [the] full ... underinsured motorist coverage.” Id. at 383 n. 1. “The effect of underinsured motorist coverage is to assure the [insured] of receiving ... the contracted amount of protection,” in the present case $100,000 total. Id. Under Rodriguez, this limit of liability clause must be given effect and enforced as written.
The majority cites to Jones v. Mid-Century Ins. Co., 287 S.W.3d 687 (Mo. banc 2009), as authority that a mathematical inability to collect the full policy amount renders an underinsured policy illusory and ambiguous. Jones is not so broad.
The Jones policy was drafted deficiently. It read:
[T]he most we will pay will be the lesser of:
1. The difference between the amount of an insured person’s damages for bodily injury, and the amount paid to that insured person by or for any person or organization who is or may be held legally liable for the bodily injury; or
2. The limits of liability of this coverage. Id. at 690.
This Court noted that the drafter had omitted the phrase “minus the amount already paid to that insured person” from the end of the second alternative. Id. at 691. Without this phrase, the plain meaning of the Jones policy seemed to promise a full amount. Id. The holding in Jones was specific to the deficient drafting of the policy that created a promise to pay the full amount. Id. It cannot be read as general adoption of a rule prohibiting limits of liability clauses.
IV. Conclusion
The plain meaning of Allied’s policy prohibited stacking of the coverage items and required a set-off for insurance already collected. Mr. Heath’s and Mr. Tomblin’s insurance policies had already paid out $60,000. Allied’s policy guaranteed that it would bring the Ritchies’ total recovery to $100,000. Thus, the proper recovery should be $40,000.
I sympathize with the Ritchies’ loss. Neither $300,000 nor $60,000 will come close to compensating them for that loss. But, the majority’s decision will have effects that reach further than the Ritchies. The majority decision increases by more *145than threefold the risk the insurance company intended to cover with this type of policy for all of its insureds. This will inextricably lead to a commensurate premium increase for all Missourians. Moreover, if insurance companies cannot write their policies with confidence that our courts will enforce their plain language, that risk will also have to be priced into our policies.
By creating ambiguities and enlarging coverage, the majority precludes insurance companies from competing in terms of coverage and price and forces higher insurance cost for all of us.
For the foregoing reasons, I respectfully dissent.
. The clause in Rodriguez read:
LIMIT OF LIABILITY
A. The limit of liability shown in the schedule for this coverage is our maximum limit of liability for all damages resulting from any one accident. This is the most we will pay regardless of the number of:
1. "Insureds";
2. Claims made;
*1433. Vehicles or premiums shown in the Declarations; or
4. Vehicles involved in the accident. Rodriguez, 808 S.W.2d at 381.
Another court commenting about the text of the Rodriguez provisions noted, "[i]t is hard to imagine clearer language.” Grinnell Select Ins. Co. v. Baker, 362 F.3d 1005, 1006 (7th Cir.2004). That court went on to further note that in almost all 50 state jurisdictions, that provision is universally enforced. Id.
. See e.g. Arditi v. Massachusetts Bonding & Insurance Co., 315 S.W.2d 736 (Mo.1958); State Farm Mutual Automobile Insurance Co. v. Western Casualty and Surety Co., 477 S.W.2d 421 (Mo. banc 1972); Planet Ins. Co. v. Ertz, 920 S.W.2d 591 (Mo.App.1996); Crown Center Redevelopment Corp. v. Occidental Fire & Casualty Co., 716 S.W.2d 348 (Mo.App.1986).
. I did not participate in the Seeck decision. Seeck departed from established Missouri law.