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 arose from a fatal two-car collision in which the minor daughter of the insured parties was killed while riding as a passenger in an uninsured vehicle driven by her father. The insured parties had a policy with the Plaintiff-Appellant covering a different vehicle, a Ford Bronco, but had deliberately chosen not to insure the Chrysler involved in the accident. The Plaintiff-Appellant sought a declaratory judgment to determine whether the uninsured motorist provision of the policy applied to the accident (paras 1-3).
Procedural History
- District Court of Lea County: The court partially granted and denied both parties' motions for summary judgment. It found no coverage under the liability or medical payments provisions of the policy but allowed coverage under the uninsured motorist provision (para 1).
Parties' Submissions
- Plaintiff-Appellant (Foundation Reserve Insurance Company): Argued that the uninsured motorist provision did not apply because the policy excluded coverage for vehicles owned by or available for the regular use of the insured or their family members. The Plaintiff relied on the precedent set in Willey v. Farmers Insurance Group to support its position (para 4).
- Defendant-Appellee (Teresa Marin): Contended that the uninsured motorist coverage was personal and not vehicle-specific. She argued that the exclusionary clause violated public policy and the express language of the New Mexico Uninsured Motorists' Insurance statute. She relied on the precedent set in Chavez v. State Farm Mutual Automobile Insurance Co. to support her claim (para 5).
Legal Issues
- Does the exclusionary clause in the uninsured motorist provision of the insurance policy violate public policy and the New Mexico Uninsured Motorists' Insurance statute?
- Is the Plaintiff-Appellant liable under the uninsured motorist coverage for the death of the insured's daughter?
Disposition
- The Supreme Court of New Mexico affirmed the district court's decision, holding that the Plaintiff-Appellant was liable under the uninsured motorist coverage (para 10).
Reasons
Per Sosa CJ (Ransom and Montgomery JJ. concurring):
The Court held that the exclusionary clause in the uninsured motorist provision of the policy was invalid because it conflicted with the public policy and the express language of the New Mexico Uninsured Motorists' Insurance statute. The Court emphasized that the purpose of uninsured motorist insurance is to protect individuals injured in automobile accidents caused by uninsured drivers and to place them in the same position as if the tortfeasor had liability insurance (paras 5-7).
The Court found that the exclusionary clause improperly limited coverage to specific vehicles, contrary to the statute's intent. It relied on the reasoning in Chavez v. State Farm Mutual Automobile Insurance Co., which invalidated a similar exclusionary provision, and expressly overruled the contrary holding in Willey v. Farmers Insurance Group (paras 5-9).
The Court concluded that the insured's daughter was an innocent victim entitled to protection under the uninsured motorist coverage, and the circumstances of her death satisfied the statutory requirements for coverage. The district court's decision was therefore affirmed in its entirety (paras 8-10).