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Petzak v. Graves

Citations: 33 Wis. 2d 175; 1967 Wisc. LEXIS 1126; 147 N.W.2d 294

Court: Wisconsin Supreme Court; January 3, 1967; Wisconsin; State Supreme Court

Narrative Opinion Summary

The case involves an appeal addressing whether a village tax assessor, referred to as Graves, qualifies as an 'executive officer' under the village's liability insurance policies, and whether his personal automobile is covered by these policies. The court analyzed the nature of Graves' duties, concluding that his role is ministerial rather than executive, which precludes classification as an 'executive officer' eligible for insurance coverage. Additionally, the court considered whether Graves' personal automobile was covered under the policies. The vehicle was not described in the insurance policies and was owned by Graves, not the village, leading the court to rule that it did not qualify for coverage. This decision was differentiated from the precedent in Severin v. Luchinske, where coverage was extended because the vehicle was owned by the insured city. Ultimately, the court affirmed the judgment, holding that neither Graves' role nor his vehicle qualified for insurance coverage under the policies in question.

Legal Issues Addressed

Classification of Executive Officer under Liability Insurance

Application: The court evaluated whether a village tax assessor qualifies as an 'executive officer' for insurance coverage purposes and determined that the role is ministerial and not executive, thus excluding coverage.

Reasoning: The court determined that Graves, as the village tax assessor, is not an 'executive officer.' Definitions from Black's Law Dictionary characterize executive officers as having the power to execute laws, while ministerial officers, like assessors, perform duties that are purely administrative without discretion.

Insurance Coverage for Automobiles under Liability Policies

Application: The court found that the automobile owned by Graves was not covered under the village's insurance policies as it was not described in the policy, distinguishing it from prior case law where the vehicle was owned by the insured entity.

Reasoning: Regarding the automobile, the court ruled that it was not covered under the policies because it was owned by Graves, not the village. For insurance coverage to apply, the vehicle must be described in the policy, which it was not.