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 concerns a dispute over the "stacking" of uninsured motorist coverages under an automobile insurance policy. The plaintiff, a class one insured under her family's multi-vehicle policy, was injured in an accident involving an underinsured motorist. She sought to stack the uninsured motorist coverages for the three vehicles listed in the policy to maximize her compensation, while the insurer denied her claim, arguing that only one coverage applied (paras 1, 4, and 8).
Procedural History
- District Court of Santa Fe County: Granted summary judgment in favor of the insurer, holding that the plaintiff was not entitled to stack the uninsured motorist coverages (para 3).
Parties' Submissions
- Plaintiff-Appellant: Argued that the policy was ambiguous regarding the premiums charged for uninsured motorist coverage and that a reasonable insured would believe they were entitled to stack the coverages. She contended that the insurer's use of the term "INCL" on the declarations page suggested multiple premiums were charged, justifying stacking (paras 11-12, 16-17).
- Defendant-Appellee: Asserted that only one premium was charged for uninsured motorist coverage, regardless of the number of vehicles insured, and that the policy clearly prohibited stacking. The insurer relied on its internal rate manual and deposition evidence to support its interpretation of the policy (para 11).
Legal Issues
- Whether the policy's language regarding uninsured motorist coverage and premiums was ambiguous.
- Whether the plaintiff was entitled to stack the uninsured motorist coverages under the policy.
Disposition
- The Supreme Court of New Mexico reversed the district court's summary judgment in favor of the insurer and remanded the case for further proceedings (para 23).
Reasons
Per Montgomery CJ (Baca and Franchini JJ. concurring):
The Court found that the policy was ambiguous in several respects, particularly regarding the use of the term "INCL" on the declarations page and the relationship between premiums and coverages. A reasonable insured could interpret the policy as charging multiple premiums for uninsured motorist coverage, thereby entitling them to stack the coverages (paras 16-17).
The Court emphasized that ambiguities in insurance policies must be construed against the insurer, as the insurer drafts the policy and has a duty to make its terms clear to the insured. The Court also noted that the policy's format and language could mislead an insured into believing they were entitled to more coverage than the insurer intended to provide (paras 14-15, 18).
The Court reiterated its strong judicial policy favoring stacking to ensure that insured individuals receive the full benefit of the coverage they have purchased. It held that the plaintiff was entitled to stack the uninsured motorist coverages and that her motion for partial summary judgment on this issue should have been granted (paras 1, 20).