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 held an automobile insurance policy with the Defendant, insuring two vehicles. She signed a waiver rejecting stacked Uninsured/Underinsured Motorist (UM/UIM) coverage, opting for non-stacked coverage at a lower premium. However, the Defendant's declaration pages showed premiums on a per-vehicle basis, leading the Plaintiff to argue that the contract was ambiguous regarding the number of premiums paid for UM/UIM insurance (paras 3-8).
Procedural History
- District Court: Granted summary judgment in favor of the Defendant, finding that the Plaintiff knowingly rejected stacked coverage and that the Defendant met all legal requirements (para 10).
- Garcia v. Allstate Fire & Cas. Ins. Co., 2024-NMCA-010: The Court of Appeals reversed the district court's decision, holding that the declaration pages rendered the premium structure ambiguous, entitling the Plaintiff to stack her coverages (para 11).
Parties' Submissions
- Plaintiff: Argued that the declaration pages created ambiguity in the contract, suggesting she paid multiple premiums for multiple coverages, and thus should be allowed to stack her UM/UIM coverage (paras 2, 9).
- Defendant: Contended that the Plaintiff knowingly waived stacked coverage by signing the waiver and selecting non-stacked coverage, and that the premiums on the declaration pages were an allocation of the single per-policy premium (paras 9, 14).
Legal Issues
- Whether the Plaintiff's waiver of stacked UM/UIM coverage was valid.
- Whether the declaration pages rendered the insurance contract ambiguous regarding the number of premiums paid for UM/UIM coverage.
Disposition
- The Supreme Court of New Mexico reversed the Court of Appeals' decision and remanded the case to the district court to reinstate its judgment in favor of the Defendant (para 23).
Reasons
Per Zamora J. (Thomson C.J., Vigil, Bacon JJ., and Hanisee J. concurring):
The Court found that the Defendant secured a valid waiver of stacked coverage from the Plaintiff, as the waiver explained the effect of stacking, offered non-stacked coverage at a lower premium, and provided an opportunity for the Plaintiff to seek additional information. The Plaintiff's signed waiver indicated her choice of non-stacked coverage (paras 14-18). The Court also determined that the contract was not ambiguous, as the waiver, declaration pages, and policy documents clearly communicated a single premium for non-stacked coverage. The declaration pages' per-vehicle premiums, when summed, matched the non-stacked premium listed on the waiver, and the policy documents explicitly stated that stacking was not permitted (paras 19-22).