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Westfield Insurance Company v. Robert Bruce Keedy Kathleen L. Keedy Individually, and as Parents and Next Friend Of, Alyssa R. Keedy, Infant Child
Citations: 23 F.3d 404; 1994 U.S. App. LEXIS 18594; 1994 WL 168305Docket: 93-2077
Court: Court of Appeals for the Fourth Circuit; May 5, 1994; Federal Appellate Court
The case involves Westfield Insurance Company (plaintiff-appellant) appealing a decision regarding an uninsured motorist claim stemming from an accident where the Keedys' vehicle collided with a refrigerator that had fallen from an uninsured pickup truck. Westfield issued an automobile insurance policy to the Keedy family, which included an uninsured motorist clause covering damages from an uninsured vehicle. On May 14, 1990, while driving in Ohio, the Keedys' car struck the refrigerator after it had been left on the road by Michelle Conaway, the owner, who abandoned her attempt to remove it. The pickup truck that dropped the refrigerator was uninsured. After the accident, Westfield denied the Keedys' claim for uninsured motorist coverage, although it compensated them for vehicle damage and medical costs. Westfield subsequently filed a lawsuit seeking a declaratory judgment that the accident did not fall under the uninsured motorist provision of the policy, arguing that the refrigerator's presence did not relate to the use of the uninsured vehicle. The district court granted summary judgment in favor of the Keedys, affirming that the accident arose "out of the use of the uninsured motor vehicle." The Fourth Circuit Court of Appeals affirmed in part and vacated and remanded in part the district court's decision. The district court denied Westfield's motion for summary judgment and ruled in favor of the Keedys, determining that the transportation of large items, like a refrigerator, was a proper use of the uninsured pick-up truck. The court found that a refrigerator falling from the truck onto the road was causally connected to the subsequent accident involving the Keedys, despite the physical and temporal distance at the time of the incident. The actions of Conaway, who spent time attempting to remove the refrigerator and returned to the accident scene, were deemed to create a continuous causal chain from the event of the refrigerator falling to the collision with the Keedy vehicle. As a result, the court concluded that Westfield was obligated to provide uninsured motorist coverage and defend the Keedys in legal proceedings. Westfield appealed, arguing that the court erred in requiring coverage for the refrigerator collision. However, upon review, the appellate court found no error and affirmed the judgment regarding the insurance coverage. The court vacated the district court's ruling on Westfield's duty to defend and remanded for dismissal of that claim without prejudice, noting a lack of substantial discussion on this issue in the record. The final judgment was affirmed in part and vacated and remanded in part.