Fort Worth Insurance Lawyers and those in Saginaw, Grapevine, Benbrook, Burleson, and other places around Tarrant County need to grasp how courts interpret the different words and phrases in an insurance contract.
The meaning of “motor vehicle accident” may seem to be an easy to understand phrase but the phrase was the subject of a lawsuit that went all the way to the Texas Supreme Court. This 2004, case is titled, “Texas Farm Bureau Mutual Insurance Company v. Jeff A. Sturrock.” Here is some background.
Jeff Sturrock drove his truck to work, parked, and turned off the engine. While exiting the truck, he entangled his left foot on the raised portion of the truck’s facing. Sturrock injured his neck and shoulder in his attempt to prevent himself from falling from the vehicle. Sturrock filed a claim for Personal Injury Protection (PIP) benefits under his vehicle’s insurance policy, issued by Texas Farm Bureau.
It should be noted that the Texas Insurance Code requires every auto policy issued in Texas to provide PIP coverage, unless rejected by the insured. Sturrock’s policy provides, in pertinent part:
A. We will pay Personal Injury Protection benefits because of bodily injury;
1. resulting from a motor vehicle accident; and
2. sustained by a covered person.
There is no dispute that Sturrock is a ‘covered person’ under the policies. The dispute is whether or not his injuries were the result from a “motor vehicle accident.”
Sturrock sued Farm Bureau for breach of contract and violations of the Texas Insurance Code. Both parties filed motions for summary judgment. The case was heard on an “Agreed Statement of Facts” pursuant to Texas Rules of Civil Procedure, wherein the trial court would apply the law to these agreed facts and determine whether Sturrock’s injuries resulted from a ‘motor vehicle accident’ within the meaning of the policy. The trial court ruled in favor of Sturrock and this appeal followed.
Farm Bureau argued that accidents like the one Sturrock experienced do not fit within the plain meaning of “motor vehicle accident” because the term requires some involvement between the covered motor vehicle and another vehicle, person, or object. Because Sturrock’s accident did not involve another vehicle or person, Farm Bureau contends Sturrock’s injuries did not result from a “motor vehicle accident.” Conversely, Sturrock claims the court has determined that a “motor vehicle accident” does not require a collision, and the incident at hand was a “motor vehicle accident” because the vehicle itself produced the injury.
The Texas Department of Insurance had weighed in on this issue asking the court to reject Farm Bureau’s argument, asserting that it posits an absurd interpretation which, if accepted, would result in greater coverage for passengers than for actual premium paying insureds.
This court said that it agreed with the Texas Department of Insurance that Farm Bureau’s cramped interpretation would severely limit an insured’s no-fault coverage in a manner that would contravene its purpose and lead to absurd results. Under Farm Bureau’s formulation, a passenger who fell from Sturrock’s truck in the same way would be covered, but Sturrock himself would not. Sturrock would be covered if he had fallen out of his car onto another person, but not if he had fallen directly onto the ground. He would be covered if a tire dislodged from another vehicle and hit his car, but not if his own tire blew out and caused his vehicle to roll over. Sturrock would be covered if he were run over by a vehicle with a faulty parking brake, but not if his own vehicle ran over him because of the same defect. Neither the policy’s language nor its context indicates a construction that would deny no-fault benefits to insureds who suffer injuries caused by their own covered vehicle.
The court pointed out that this is not to say that any accident involving another vehicle, an object, or a person constitutes a “motor vehicle accident.” While a collision or near collision is not required, the vehicle must be more that the mere situs of the accident or injury producing event.
If Sturrock had finished exiting the truck and then fell, or if he had fallen out of the car without any involvement of the vehicle, there would be no coverage. But here, the vehicle’s door facing was a causative factor in Sturrock’s fall.
In conclusion, the court said, “We hold that a ‘motor vehicle accident’ occurs when (1) one or more vehicles are involved with another vehicle, an object, or a person, (2) the vehicle is being used, including exit or entry, as a motor vehicle, and (3) a casual connection exists between the vehicle’s use and the injury producing event. Here, Sturrock was injured when his left foot became entangled with his car’s facing while he was exiting the vehicle. We conclude that Sturrock’s injury resulted from a ‘motor vehicle accident’ within the policy’s terms, and affirm the judgment.”
In this case, four of the nine Judges disagreed with the ruling. This fact serves as a reminder why an experienced Insurance Law Attorney needs to be consulted on these insurance claims.
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