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 domestic partner sought underinsured motorist benefits under automobile insurance policies issued to her partner, the named insured. The insurance companies denied coverage, arguing that the claimant did not qualify as a "family member" under the policies, as New Mexico does not recognize common-law marriage. The claimant was listed as a driver but not as a named insured (paras 1-2).
Procedural History
- Federal District Court: Held that the claimant was not entitled to underinsured motorist benefits because New Mexico does not recognize common-law marriage, and Class I insurance coverage does not extend to domestic partners (para 2).
Parties' Submissions
- Appellants (Defendants-Counter-Claimants): Argued that excluding domestic partners from the definition of "family member" in automobile insurance policies violates New Mexico public policy, citing judicial, executive, and legislative actions recognizing domestic partnerships (paras 3, 6-9).
- Appellees (Plaintiffs-Counter-Defendants): Contended that the policies' definition of "family member" was valid and consistent with New Mexico law, as the state does not recognize common-law marriage or extend automatic contractual rights to domestic partners (paras 12-13).
Legal Issues
- Is excluding domestic partners from the definition of "family member" in an automobile insurance policy invalid as contrary to the public policy of New Mexico? (para 2).
Disposition
- The Supreme Court of New Mexico held that excluding domestic partners from the definition of "family member" in automobile insurance policies is not contrary to New Mexico public policy (para 15).
Reasons
Majority Opinion (Per Chávez J., with Bosson C.J., Minzner J., and Maes J. concurring):
The Court found no clear legislative or statutory mandate in New Mexico requiring domestic partners to be included in the definition of "family member" for automobile insurance purposes. While judicial, executive, and legislative actions have recognized certain rights for domestic partners, these do not extend to automatic contractual rights akin to those of married couples. The Court emphasized that public policy is primarily determined by the legislature, and the absence of legislative action on this issue supports the validity of the insurance policies' definitions. The Court also noted that domestic partners could secure coverage by explicitly listing themselves as named insureds (paras 3-15).
Dissenting Opinion (Serna J.):
Justice Serna dissented, arguing that the exclusion of domestic partners from the definition of "family member" violates New Mexico public policy. He highlighted the couple's long-term relationship and mutual dependency, as well as legislative and executive actions supporting domestic partnerships. Justice Serna contended that the insurance companies failed to clarify coverage expectations and that the Court should uphold the reasonable expectations of insureds. He concluded that the claimant should be considered a "family member" under the policy (paras 17-25).