This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A Santa Fe automobile dealership, Crawford Chevrolet, Inc., agreed to provide a new vehicle as a prize for any participant scoring a hole-in-one on a designated hole during a pro-am golf tournament. Crawford obtained insurance from National Hole-in-One Association (Hole-in-One) to cover this risk. During the tournament, a golfer scored a hole-in-one on the designated physical hole (#9) during their second round on the nine-hole course. Hole-in-One denied coverage, arguing the contract only insured against a hole-in-one on the first round of play on the designated hole (paras 1-6).
Procedural History
- Trial Court, Santa Fe County: The trial court ruled in favor of Crawford Chevrolet, finding the insurance contract ambiguous and construing it in favor of the insured. It awarded $19,796.00 in damages and costs (paras 7-8).
Parties' Submissions
- Appellant (Hole-in-One): Argued that the insurance contract was unambiguous and only provided coverage for a hole-in-one scored on the designated hole during the first round of play. Alternatively, it contended that damages should be reduced because Crawford understated the number of shots in its application (paras 8, 19).
- Appellee (Crawford Chevrolet): Claimed the contract was ambiguous, particularly regarding the term "hole #9" and the "number of shots," and should be interpreted in favor of the insured to provide coverage for the hole-in-one scored during the second round (paras 7, 11).
Legal Issues
- Was the insurance contract ambiguous regarding coverage for a hole-in-one scored on the second round of play on the designated hole?
- Should the damages awarded to Crawford Chevrolet be reduced due to an alleged understatement of the number of shots in the insurance application?
Disposition
- The Supreme Court of New Mexico affirmed the trial court's judgment, holding that the insurance contract provided coverage for the hole-in-one scored during the second round and that damages should not be reduced (paras 18-19, 21).
Reasons
Per Montgomery J. (Baca J. concurring):
The Court found the insurance contract ambiguous, particularly regarding the term "shots," which could reasonably be interpreted as either the number of attempts to score a hole-in-one or the number of players participating. The Court determined that the parties intended "shots" to mean "number of players," based on the language in the application and correspondence between the parties. This interpretation supported coverage for the hole-in-one scored during the second round of play (paras 12-16).
The Court also rejected Hole-in-One's argument for reducing damages, as Crawford accurately reported the number of players, and there was no variance in the number of shots (para 19).
Special Concurrence by Ransom C.J.:
Ransom C.J. expressed reluctance but concurred, acknowledging that the ambiguity in the terms "shots" and "holes" could reasonably lead to the majority's interpretation. However, he personally found the risk underwritten by Hole-in-One to be unambiguous (para 23).