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 Plaintiffs were injured in a collision involving a 1997 Ford Expedition driven by the insured under a Hartford Insurance policy. The Expedition was owned by the insured's spouse and was not listed on the Hartford policy's declarations page. The insured regularly used the Expedition for both personal and business purposes. The Plaintiffs sought coverage under the Hartford policy, but the insurer denied the claim, citing policy exclusions for "owned vehicles" and "regular use" (paras 1-3).
Procedural History
- District Court of Bernalillo County: Granted summary judgment in favor of Hartford Insurance, concluding that the policy exclusions barred coverage for the Plaintiffs' claims (para 1).
Parties' Submissions
- Plaintiffs-Appellants: Argued that Hartford was obligated to provide coverage under the insured's policy and that the exclusions were improperly applied. They also contended that the policy language was ambiguous and should be interpreted in their favor (paras 1, 10-11, 16).
- Defendant-Appellee (Hartford Insurance): Asserted that the "owned vehicle" and "regular use" exclusions in the policy barred coverage. They argued that the policy language was clear and unambiguous, and the exclusions were properly applied (paras 9-10, 16).
Legal Issues
- Did the "owned vehicle" exclusion in the Hartford policy bar coverage for the Plaintiffs' claims?
- Did the "regular use" exclusion in the Hartford policy bar coverage for the Plaintiffs' claims?
- Was the policy language ambiguous, and should it be interpreted in favor of the Plaintiffs?
Disposition
- The Court of Appeals affirmed the trial court's decision, holding that both the "owned vehicle" and "regular use" exclusions barred coverage under the Hartford policy (para 23).
Reasons
Per Pickard J. (Sutin CJ and Kennedy J. concurring):
Owned Vehicle Exclusion: The Court held that the "owned vehicle" exclusion applied because the Expedition was owned by the insured's spouse, who was a resident of the same household. The policy defined "you" and "your" to include both the named insured and their spouse. The Court found no ambiguity in the policy language and rejected the Plaintiffs' argument that the exclusion should only apply to vehicles owned by the named insured (paras 10-17).
Regular Use Exclusion: The Court determined that the Expedition was furnished for the insured's regular use, as it was consistently available to him for both personal and business purposes. Substantial evidence supported the trial court's finding that the insured's use of the vehicle was regular rather than incidental (paras 21-22).
Policy Ambiguity: The Court rejected the Plaintiffs' claim that the policy was ambiguous due to overlapping definitions of "spouse" and "family member." It found that the terms were distinct and did not create ambiguity. Consequently, the Plaintiffs' reasonable expectations argument also failed (paras 16-17).
Summary Judgment: Since the coverage claims were dispositive of all other claims, the Court affirmed the trial court's grant of summary judgment in favor of Hartford on all claims (para 23).