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 case involves an accident where a tractor and trailer, each insured under the same policy with liability limits of $1 million, were negligently operated by an employee of the insured, resulting in a collision with a vehicle driven by Plaintiff Edward Lucero, Jr. Edward Lucero, Jr. was injured, and Elaine Lucero, his wife, also claimed damages from the accident (para 2).

Procedural History

• District Court of McKinley County: Granted summary judgment to Defendant insurer, holding that the insurance policy limited liability coverage for both the tractor and the trailer to $1 million (para 1).

Parties' Submissions

• Plaintiffs: Argued that the tractor and trailer were two separate vehicles, each entitled to $1 million in liability coverage under the policy, making the total liability coverage $2 million for the accident. Contended that the anti-stacking clause was inapplicable as they were not seeking to stack coverages but rather to claim the coverage purchased for each vehicle involved (para 6).
• Defendant: Contended that the policy unambiguously limited liability coverage to $1 million per accident and that the anti-stacking clause established that only one liability coverage amount of $1 million was available for any single accident (para 6).

Legal Issues

• Whether the insurance policy's limit of liability or anti-stacking clause restricts liability coverage to the limits applicable to only one of two covered vehicles involved in the same accident.
• Whether the anti-stacking clause is applicable or creates an ambiguity in the policy when two covered vehicles are involved in the same accident.

Disposition

• The Court of Appeals of New Mexico reversed the district court's decision and remanded with instructions to enter summary judgment declaring the liability limits to be $2 million—$1 million for each covered vehicle involved in the accident (para 1).

Reasons

• The Court, per Cynthia A. Fry, J., with Timothy L. Garcia, J., and J. Miles Hanisee, J., concurring, found that the anti-stacking clause conflicted with the liability coverage provisions of the policy, creating an ambiguity that requires interpretation in favor of the insured. The Court determined that the policy intended to provide $1 million in liability coverage for each covered vehicle involved in an accident, leading to a total liability limit of $2 million for the accident in question. The Court rejected the defendant's arguments that a tractor and trailer operated in tandem constitute one vehicle under New Mexico and federal law, and that the anti-stacking provision precludes aggregating more than one vehicle’s liability coverage. The Court concluded that the reasonable expectations of the insured were that the policy would provide $1 million in liability coverage for each covered vehicle involved in an accident, even if it was the same accident (paras 10-27).