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Primeaux v. State Farm Mutual Automobile Insurance Co.

Citations: 624 So. 2d 1294; 1993 La. App. LEXIS 2941; 1993 WL 394607Docket: No. 92-1446

Court: Louisiana Court of Appeal; October 6, 1993; Louisiana; State Appellate Court

Narrative Opinion Summary

In this case, the appellant sought to recover uninsured motorist (UM) benefits under a State Farm policy after being injured in a vehicle accident involving a family-owned GMC van. The GMC van was insured by State Farm, which had already paid the liability limits of that policy. The appellant aimed to claim additional UM benefits from a separate policy covering a different vehicle, a Nissan 200 SX. State Farm filed a motion for summary judgment, asserting that UM coverage was excluded under La.R.S. 22:1406(D)(1)(e) because the appellant was injured while occupying a vehicle not described in the policy from which she sought coverage. The trial court granted summary judgment in favor of State Farm. On appeal, the court relied on statutory amendments and precedent set by Sandoz v. State Farm, confirming the exclusion's validity. The appellate court upheld the trial court's decision, denying UM benefits under the Nissan policy and assigning all appeal costs to the appellant.

Legal Issues Addressed

Affirmation of Trial Court's Summary Judgment

Application: The appellate court upheld the trial court's decision, reinforcing the enforceability of exclusionary provisions in UM policies under the amended statute.

Reasoning: The appellate court affirmed the trial court's judgment, holding that Primeaux cannot recover UM benefits under the Nissan policy while occupying the GMC van.

Precedent and Consistency with Prior Case Law

Application: The appellate court cited the Sandoz v. State Farm decision to support the denial of UM coverage, aligning with the interpretation of similar exclusionary provisions.

Reasoning: The case parallels the previously adjudicated Sandoz v. State Farm, where similar UM coverage issues were addressed.

Uninsured Motorist Coverage Exclusions under La.R.S. 22:1406(D)(1)(e)

Application: The court applied this statute to exclude UM coverage for injuries sustained by Primeaux while occupying a family-owned vehicle not described in the insurance policy.

Reasoning: State Farm's motion for summary judgment argued that Primeaux was not eligible for UM benefits under the Nissan policy due to specific provisions that exclude UM coverage when an insured is occupying a vehicle owned by them that is not described in the policy under which the claim is made.