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 part-time employee of a school district was injured in a car accident while driving a school district vehicle. The employee claimed she had permission to use the vehicle for both personal and work-related errands on the day of the accident. The accident occurred during a personal detour, and the employee sought damages under the uninsured motorist provision of the school district’s insurance policy. The policy excluded coverage for employees injured in the course of their employment (paras 2-3, 5).
Procedural History
- District Court of Doña Ana County: Granted summary judgment in favor of the New Mexico Public School Insurance Authority, finding no genuine issue of material fact and holding that the employee was excluded from coverage under the policy (headnotes, para 1).
Parties' Submissions
- Plaintiffs-Appellants: Argued that the employee was covered under the uninsured motorist provision of the policy because she had permission to use the vehicle and was not acting within the course of her employment at the time of the accident. They also contended that the exclusion for employees was invalid or inapplicable (paras 4, 8-9).
- Defendant-Appellee: Asserted that the policy explicitly excluded uninsured motorist coverage for employees injured in the course of their employment and that the employee was acting within the scope of her employment at the time of the accident. They also argued that the school district had lawfully rejected uninsured motorist coverage for employees (paras 4-6).
Legal Issues
- Was the employee covered under the uninsured motorist provision of the school district’s insurance policy despite the employee exclusion?
- Did the employee’s actions at the time of the accident fall outside the scope of her employment, thereby invalidating the exclusion?
Disposition
- The Supreme Court of New Mexico affirmed the trial court’s decision, holding that the employee was excluded from coverage under the policy (para 11).
Reasons
Per Franchini J. (Frost and Minzner JJ. concurring):
The court found that the insurance policy explicitly excluded uninsured motorist coverage for employees injured in the course of their employment. The court emphasized that the exclusion was valid under New Mexico law, which allows employers to reject such coverage for employees (paras 5-6).
The court rejected the plaintiffs’ argument that the employee was not acting within the course of her employment at the time of the accident. It held that even if the employee temporarily deviated from her duties, she was still considered to be acting within the scope of her employment under the terms of the policy (para 11).
The court also distinguished the case from Allstate Insurance Co. v. Jensen, which involved liability coverage for third parties, noting that the present case concerned uninsured motorist coverage for an employee (para 7).
The court concluded that the policy’s exclusion was enforceable and that no genuine issue of material fact existed to preclude summary judgment (para 11).