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Brown v. Farmers Insurance Group

Citations: 31 Wash. App. 593; 643 P.2d 926; 1982 Wash. App. LEXIS 2683Docket: No. 8972-2-I

Court: Court of Appeals of Washington; April 19, 1982; Washington; State Appellate Court

Narrative Opinion Summary

The case involves an appeal by the insured party, who sought coverage under the 'uninsured motorist' provision of her automobile insurance policy following a collision with a riderless horse. The appellant argued that the horse should be considered an 'uninsured vehicle' under her policy. However, the policy explicitly defined a 'vehicle' as a mechanical device used for transportation on public highways, thereby excluding the horse from coverage. The trial court granted summary judgment in favor of the insurer, Farmers Insurance Group, concluding that a horse did not meet the policy's definition of a vehicle. The appellate court affirmed this decision, emphasizing that the term 'device' is understood to refer to mechanical entities and highlighting that 'uninsured motorist' provisions are designed to protect against negligent operators of motor vehicles. The court's decision reiterated that the intent of such provisions is to cover incidents involving motor vehicles, not animals or non-mechanical entities. Consequently, the judgment in favor of Farmers Insurance Group was upheld, with the appellate court concurring unanimously.

Legal Issues Addressed

Definition of 'Vehicle' in Insurance Policies

Application: The court determined that a horse does not qualify as a 'vehicle' under the insurance policy's definition, which is limited to mechanical devices used for transporting persons or property on public highways.

Reasoning: The policy defined 'vehicle' as any device used for transporting persons or property on public highways, excluding devices moved by human power or used solely on stationary tracks. The trial court ruled that a horse did not meet this definition.

Interpretation of 'Device' in Legal Context

Application: The court interpreted 'device' as typically referring to mechanical objects, thereby excluding a horse from being considered under this definition.

Reasoning: The appellate court concurred, emphasizing that the term 'device' is typically understood to mean something mechanical, which a horse is not.

Scope of 'Uninsured Motorist' Provisions

Application: The court affirmed that 'uninsured motorist' provisions are intended to provide protection against negligent drivers of motor vehicles, not incidents involving non-vehicles such as horses.

Reasoning: The court also highlighted that the public policy behind 'uninsured motorist' provisions is to protect against negligent drivers of motor vehicles, not against incidents involving non-motor vehicles like horses.