Law School Case Brief
Roy v. State Farm Mut. Auto. Ins. Co. - 954 F.2d 392 (6th Cir. 1992)
Liability insurance provides indemnification for people, not objects. It is not a logical necessity that a vehicle be treated as uninsured, from the standpoint of an accident victim, if the insurance company by which the victim will be paid pursuant to the company's indemnification responsibility happens to have promised to indemnify the driver and not the owner.
A head-on motor vehicle collision resulted in one of the drivers killed and his passenger and the other driver were seriously injured. Plaintiff Nelva Roy, the decedent's administratrix, together with the injured passenger and his wife, filed a lawsuit federal district court against their own automobile insurance carriers, defendants State Farm Mutual Automobile Insurance Company and Capital Enterprise Insurance Company ("Insurers"). Plaintiffs contended that their policies entitled them to be paid for their uncompensated damages because, although the driver who caused the accident had the minimum liability coverage required by state law, the owner of the vehicle he was operating had no liability coverage. Specifically, plaintiffs sought underinsured motorist coverage for uncompensated injuries as well as uninsured benefits. The parties filed competing motions for summary judgment. The trial court granted the insurers' motions, which claimed that no coverage was due. Plaintiffs appealed.
Were the insurance carriers liable?
The appellate court affirmed the trial court's grant of summary judgment to the Insurers, holding that, where the driver of the vehicle injuring plaintiffs was insured for state minimum coverage, insurance for the accident existed, and plaintiffs were not entitled to uninsured motorists coverage. Valid and collectible insurance existed with that vehicle's driver, and plaintiffs were not entitled to uninsured motorist coverage. The court added that the decedent's insurance policy was unambiguous, and provided no additional underinsured motorist coverage. Where the insured did not opt for additional underinsurance coverage, none was applicable.
Access the full text case
Not a Lexis Advance subscriber? Try it out for free.
Be Sure You're Prepared for Class