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Ka Ying Vue v. State Farm Insurance Companies
Citations: 568 N.W.2d 527; 1997 WL 556020Docket: C1-97-632
Court: Court of Appeals of Minnesota; November 18, 1997; Minnesota; State Appellate Court
Appellants Ka Ying Vue and Ker Vang appealed the district court's summary judgment favoring State Farm Insurance Companies, which denied Vue uninsured motorist benefits due to the Skylark, owned by Vang, being uninsured at the time of the accident. The court found that the insurance policy excluded coverage for bodily injury to any insured occupying an uninsured vehicle owned by the insured. Vue contended that she was not an owner of the Skylark, making the exclusion inapplicable to her. The Minnesota No-Fault Automobile Insurance Act defines a vehicle owner as one who holds legal title, which in this case is Vang. State Farm argued for a broader interpretation that would include Vue as a spouse; however, the court rejected this argument, stating that without legislative intent to classify spouses as constructive owners, the exclusion did not apply to Vue. Thus, the appellate court reversed the district court’s decision and remanded the case for further proceedings. Vang solely purchased and titled the car, indicating that Vue, despite being a licensed driver, does not own the vehicle. Consequently, the policy exclusion regarding ownership does not apply, and the district court incorrectly denied Vue uninsured motorist benefits. State Farm contends that Vang, as the car's owner, is excluded from recovering loss of consortium benefits related to his wife's injuries. However, loss of consortium benefits arise from the injured spouse's claim against a tortfeasor and are not classified as 'bodily injury,' but rather as an injury to the marital relationship. Since the policy's uninsured motorist exclusion applies only to bodily injury, Vang remains eligible for loss of consortium benefits. The district court's summary judgment is reversed, and the case is remanded for trial concerning Vue's injuries and Vang's loss of consortium claim. Additionally, it was established that the Skylark was not a newly acquired vehicle under the policy and thus uninsured. Vang has a separate personal injury claim against State Farm, which was dismissed without appeal. Vue also contends that the district court mistakenly assumed the Skylark was the uninsured vehicle in question; this claim is based on the uninsured status of another driver.