Bear River Mutual Insurance Co. v. Wright
Docket: 880249-CA
Court: Court of Appeals of Utah; March 23, 1989; Utah; State Appellate Court
In the case of Bear River Mutual Insurance Company v. Robert Wright and Mark Martinez, the Utah Court of Appeals addressed the applicability of uninsured motorist coverage in an automobile insurance policy regarding a motorcycle owned by the insured but not explicitly listed in the policy. The court noted that the issue was influenced by a prior decision from the Utah Supreme Court (Clark v. State Farm Mut. Auto. Ins. Co.), which established that an insurer could exclude coverage for a vehicle owned by the insured that was not specifically named in the policy. However, the court highlighted that the language of the Bear River Mutual policy significantly differed from that in the Clark case. The appellant, Wright, contended that the policy's uninsured motorist provisions did not exclude coverage for his motorcycle. The court agreed with Wright's position, concluding that the policy should extend coverage to him for damages resulting from an accident involving an uninsured motorist, thereby reversing the summary judgment in favor of Bear River Mutual. The policy explicitly provided coverage for damages from uninsured vehicles but included exclusions that did not apply to the specific circumstances of Wright’s claim. Coverage under the insurance policy is excluded for injuries sustained while operating an unlisted "automobile" owned by the insured. The exclusion's interpretation is guided by its clear language and is subject to narrow construction, particularly when the policy includes broad coverage terms. The policy's language should be enforced as written unless ambiguity exists. Specifically, the determination of whether a motorcycle qualifies as an "automobile" under the policy hinges on the definitions provided therein and common understanding. The policy defines "automobile" as a passenger vehicle, typically with four wheels, while a "motorcycle" is defined as a two-wheeled vehicle, suggesting a motorcycle is not considered an "automobile." The absence of motorcycle inclusion in the policy's definitions reinforces this interpretation. Bear River Mutual's reference to previous cases does not substantiate its position, as the relevant policy language differs and lacks clarity. Ultimately, the legislative intent underscores that coverage pertains to the vehicle itself rather than the named insured, aligning with the court's decision. An insurer is not statutorily required to provide uninsured motorist coverage for vehicles not listed in the policy when the insured is operating such vehicles. However, the insurer can voluntarily offer broader coverage as per the policy's language. Bear River Mutual's policy covers injuries caused by uninsured motorists, explicitly excluding only uninsured "automobiles" owned by the insured, thus not excluding coverage when the insured operates a motorcycle. The summary judgment is reversed, and the case is remanded for further proceedings. Supporting case law indicates that insurers may contract for greater coverage than what is mandated by statute without conflicting with public policy. Additionally, terms in legal documents are presumed to be used in their ordinary sense unless a different interpretation is warranted by legislative context. Recent changes in definitions have expanded the term "motor vehicle" to include motorcycles.