AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Plaintiff, after initially insuring a single vehicle with Allstate, added a second vehicle to her policy and selected "non-stacked" uninsured/underinsured motorist (UM/UIM) coverage. Despite selecting a single premium for "non-stacked" coverage, the declarations page listed UM/UIM coverage and premium charges on a vehicle-by-vehicle basis. Following an accident, the Plaintiff sought to stack her UM/UIM coverages, arguing that the payment of multiple premiums entitled her to stacked coverage. Allstate declined, leading to the lawsuit (paras 2-4).

Procedural History

• District Court of Curry County: The court granted summary judgment in favor of Allstate, concluding that the Plaintiff had validly selected "non-stacked" UM/UIM coverage and that Allstate had complied with all requirements for a valid rejection of uninsured motorist coverage (para 5).

Parties' Submissions

• Plaintiff-Appellant: Argued entitlement to $50,000 in stacked UM/UIM bodily injury coverage based on the payment of separate premiums for each vehicle insured under the policy (para 5).
• Defendant-Appellee: Maintained that the Plaintiff was not entitled to stacked coverage because she had executed a valid rejection of such coverage, asserting that only one premium for one coverage was charged, allocated among the insured vehicles (paras 5, 11).

Legal Issues

• Whether the Defendant's premium structure for UM/UIM coverage on a multi-vehicle policy is ambiguous, entitling the Plaintiff to stack her UM/UIM coverages (para 1).
• Whether there was a valid written offer of UM/UIM coverage and whether the Plaintiff's rejection was properly incorporated into the policy.

Disposition

• The Court of Appeals reversed the district court's decision and remanded for further proceedings, holding that the insurance contract was ambiguous regarding whether multiple premiums were charged, thus entitling the Plaintiff to stack her coverages (para 18).

Reasons

• Per Duffy, J. (Attrep, C.J., and Medina, J., concurring): The Court found the insurance contract ambiguous as to whether multiple premiums were charged for UM/UIM coverage, given the policy's presentation of premiums on a vehicle-by-vehicle basis on the declarations page. This ambiguity, under established New Mexico Supreme Court precedent, entitles an insured to stack coverages when separate premiums are paid for each vehicle under a multi-vehicle policy. The Court concluded that a reasonable insured could believe they were paying multiple premiums, thus entitling the Plaintiff to stack her UM/UIM coverages. The Court did not address other arguments due to its conclusion on the ambiguity of the premium structure (paras 6-17).