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 Plaintiff, an employee of New Mexico Security Patrol, Inc. (NMSP), was rendered paraplegic in a motor vehicle accident caused by a negligent underinsured motorist while driving a company-insured vehicle. NMSP held a business auto insurance policy with United States Fidelity & Guaranty Company (USF&G), which included uninsured/underinsured motorist coverage for five vehicles. USF&G paid the Plaintiff $60,000, the policy limit for the vehicle involved, but refused to allow stacking of coverage from the other four vehicles, despite the Plaintiff's injuries exceeding $300,000 (paras 1-2).
Procedural History
- District Court of Chaves County: Found in favor of USF&G, ruling that the Plaintiff was not entitled to stack coverage under the policy (para 2).
Parties' Submissions
- Plaintiff-Appellant: Argued that the policy's language created an ambiguity regarding whether he qualified as a class-one insured, which would entitle him to stack coverage for all five vehicles (paras 4, 6-7).
- Defendant-Appellee: Contended that the Plaintiff, as an employee, was a class-two insured under the policy and therefore not entitled to stack coverage. They argued that the policy unambiguously excluded employees from class-one coverage (paras 5, 11).
Legal Issues
- Was the Plaintiff a class-one insured under the policy, allowing him to stack uninsured motorist coverage for all five vehicles?
- Did the policy's language create an ambiguity that must be construed against the insurer?
Disposition
- The Supreme Court of New Mexico reversed the trial court's decision and remanded the case with instructions to enter judgment in favor of the Plaintiff for $240,000 (para 15).
Reasons
Majority Opinion (Per Sosa CJ., Baca J., and Alarid J. concurring):
The Court found that the policy's language defining class-one insureds as "you or any family member" created a patent ambiguity when applied to a corporate insured like NMSP. The term "family member" was nonsensical in the context of a corporation, and the ambiguity must be construed against the insurer under New Mexico law (paras 6-8). The Court rejected USF&G's argument that the Plaintiff was unambiguously a class-two insured, reasoning that the policy's language did not explicitly exclude employees from class-one coverage (paras 7, 11). Drawing on precedent and analogous cases, the Court held that the Plaintiff qualified as a class-one insured and was entitled to stack coverage for the other four vehicles (paras 9-14).
Dissenting Opinion (Ransom J.):
Justice Ransom dissented, arguing that the attachment of a family or individual rider to the business policy did not create an ambiguity. He maintained that the term "family member" clearly referred to household residents related by blood, marriage, or adoption, and there was no evidence that the parties intended to include employees as class-one insureds (para 17).