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 filed a complaint against the Defendant insurance company and a tortfeasor for personal injuries, seeking uninsured motorist (UM) benefits, among other claims. The Plaintiff served the insurance company, but it did not respond, leading to a default judgment against the tortfeasor. The Plaintiff then moved for partial summary judgment against the insurance company, which was initially granted. However, the insurance company later appeared and moved to set aside the partial summary judgment (paras 2-3).
Procedural History
- District Court, September 27, 2021: Default judgment for damages was entered against the tortfeasor.
- District Court, January 19, 2022: Partial summary judgment was granted in favor of the Plaintiff against the insurance company.
Parties' Submissions
- Plaintiff: Argued that the district court applied the incorrect legal standard in setting aside the partial summary judgment and that there were disputed questions of fact regarding the definition of "insured" in the policy, which should prevent summary judgment in favor of the insurance company (paras 1, 5).
- Defendant (Loya Insurance Company): Contended that the district court correctly set aside the partial summary judgment under Rule 1-055(C)'s "good cause" standard and that the policy unambiguously defined who was an "insured" for UM coverage (paras 6, 13).
Legal Issues
- Whether the district court applied the incorrect legal standard in setting aside the partial summary judgment.
- Whether there were disputed questions of fact regarding the definition of "insured" in the insurance policy that should prevent summary judgment in favor of the insurance company.
Disposition
- The district court did not abuse its discretion in setting aside the partial summary judgment order.
- The district court's summary judgment in favor of the insurance company was reversed in part due to ambiguities in the policy regarding the Plaintiff's status as an "insured" (para 1).
Reasons
Per Wray J. (Bogardus and Ives JJ. concurring):
The district court had the inherent authority to set aside its interlocutory order granting partial summary judgment, and it did not abuse its discretion in doing so. The court found that the insurance policy contained ambiguities regarding the definition of "insured" for UM coverage, particularly due to extrinsic evidence such as the insurance card and policy change forms. These documents created a reasonable expectation of coverage for the Plaintiff, leading to the conclusion that the Plaintiff was an insured for the purposes of UM coverage. The court reversed the summary judgment in favor of the insurance company on this basis (paras 6-15).