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Lorrie Murphy v. Jessica Chadwell

Citation: Not availableDocket: 02A01-9705-CV-00105

Court: Court of Appeals of Tennessee; March 16, 1998; Tennessee; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this appellate case, the court addressed a dispute between an individual plaintiff, acting for herself and her daughter, and Mid-Century Insurance Company regarding coverage under an automobile insurance policy. The plaintiff sought uninsured motorist benefits following an accident involving a 1985 Chevrolet Camaro, which she drove regularly, and an uninsured vehicle driven by a third party. The primary legal issues involved the interpretation of 'uninsured motor vehicle' and 'regular use' within the insurance policy. The trial court granted summary judgment to Mid-Century, determining that the Camaro did not qualify as an uninsured motor vehicle because it was regularly available for the plaintiff’s use, thus falling under policy exclusions. The plaintiff's argument of ambiguity in the term 'regular use' was rejected, as the court found the term clear and unambiguous based on the frequency of use. Additionally, the exclusion for bodily injuries sustained while occupying a family member's uninsured vehicle was upheld, barring the daughter's claim. The appellate court affirmed the trial court's judgment, concluding that no genuine issues of material fact existed, and the insurer was entitled to judgment as a matter of law.

Legal Issues Addressed

Ambiguity in Insurance Contract Terms

Application: The court determined that the term 'regular use' was clear and unambiguous, rejecting the Plaintiff's claim that it was ambiguous and created a genuine issue of material fact.

Reasoning: The term 'regular use' is deemed clear and unambiguous, indicating that the Plaintiff's usage of the 1985 Camaro qualifies as regular.

Definition of 'Uninsured Motor Vehicle' under Insurance Policy

Application: The court applied the policy's definition of 'uninsured motor vehicle' to determine that the Camaro did not qualify as such because it was regularly available for the Plaintiff's use.

Reasoning: Mid-Century's motion for summary judgment argued that the Camaro did not qualify as an 'uninsured motor vehicle' under the policy, citing a provision that excludes vehicles regularly available for use by the insured or family members.

Exclusion Provisions in Insurance Policies

Application: The court upheld the exclusion provision that barred coverage for injuries sustained while occupying a vehicle owned by a family member and not insured under the policy, applying this to deny the Daughter's claim.

Reasoning: Mid-Century argues that Daughter should be denied recovery based on a policy exclusion for bodily injuries sustained while occupying a vehicle owned by a family member that is not insured under the policy.

Interpretation of 'Regular Use' in Insurance Contracts

Application: The court found that the Plaintiff's use of the Camaro 3 to 4 times a week constituted 'regular use,' thus excluding coverage under the policy.

Reasoning: Evidence shows the car was consistently accessible to the Plaintiff, who reported using it 3-4 times weekly, clearly fitting the common definition of regular use.

Standard for Granting Summary Judgment

Application: The appellate court affirmed the summary judgment in favor of Mid-Century, finding no genuine issue of material fact and that the insurer was entitled to judgment as a matter of law.

Reasoning: The court reviews the summary judgment de novo, emphasizing that such a judgment is appropriate when there are no genuine material facts at issue and the moving party is entitled to judgment as a matter of law.