AI Generated Opinion Summaries

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 Defendant was injured in a car accident in Mexico, within fifty miles of the U.S. border, while traveling as a passenger in a vehicle that collided with an uninsured motorist. The Defendant sought uninsured motorist benefits under her automobile insurance policy with the Plaintiff. The Plaintiff denied the claim, citing a territorial limitation in the policy that restricted uninsured motorist coverage to the United States, its territories and possessions, and Canada (paras 2-3).

Procedural History

• District Court, Bernalillo County: Granted summary judgment in favor of the Plaintiff, holding that the territorial limitation in the policy precluded the Defendant from receiving uninsured motorist benefits for the accident in Mexico (para 3).

Parties' Submissions

• Plaintiff (State Farm Mutual Automobile Insurance Company): Argued that the plain language of the policy excluded uninsured motorist coverage in Mexico and that the territorial limitation was valid and enforceable (para 3).
• Defendant (Librada Marquez): Contended that New Mexico public policy requires uninsured motorist coverage to be territorially coextensive with liability coverage and that the territorial limitation in the policy was invalid (para 3).

Legal Issues

• Does New Mexico public policy require uninsured motorist coverage to be territorially coextensive with liability coverage?
• Was the territorial limitation on uninsured motorist coverage in the Defendant's policy valid and enforceable?

Disposition

• The Court of Appeals reversed the District Court's decision and remanded the case for further proceedings (para 14).

Reasons

Per Pickard J. (Armijo and Castillo JJ. concurring):

• The Court held that New Mexico public policy, as embodied in the uninsured motorist statute (NMSA 1978, § 66-5-301), requires uninsured motorist coverage to be territorially coextensive with liability coverage. The statute aims to place an injured policyholder in the same position as if the uninsured motorist had liability insurance, and its remedial purpose must be liberally construed to achieve this objective (paras 5-7).
• The Court distinguished the case from Dominguez v. Dairyland Ins. Co., 1997-NMCA-65, where territorial limitations were upheld because they applied to the entire policy. Here, the territorial limitation applied only to uninsured motorist coverage, making it inconsistent with the statutory purpose and public policy (paras 7-8).
• The Court found support in decisions from other jurisdictions, which generally hold that territorial limitations on uninsured motorist coverage are invalid if they are more restrictive than those on liability coverage. The Court rejected contrary reasoning from New Hampshire, emphasizing the remedial purpose of New Mexico's uninsured motorist statute (paras 9-12).
• The Court concluded that the territorial limitation in the Defendant's policy was void because it imposed greater restrictions on uninsured motorist coverage than on liability coverage. The Court did not address whether an insurer could validly limit uninsured motorist coverage through a specific rejection that complies with regulatory requirements (para 13).