Matter of State Farm Mut. Auto. Ins. Co. v. Fitzgerald

The Court of Appeals held in Matter of State Farm Mut. Auto. Ins. Co. v. Amato that N.Y. Ins. Law 3420(f), which provides that all motor vehicle insurance policies must contain uninsured motorist coverage, has no application to police vehicles. Here, Respondent, a police officer, was injured when the driver of an underinsured vehicle struck the police car in which Respondent was a passenger and Michael Knauss was the driver. Knauss maintained an automobile liability insurance policy issued by State Farm that included a supplementary uninsured/underinsured motorist (SUM) endorsement. Respondent made a demand upon State Farm for underinsured motorist arbitration under the SUM endorsement of Knauss’s policy. State Farm refused payment, asserting that a police vehicle was not a covered “motor vehicle” within the meaning of the SUM endorsement. Supreme Court concluded that Knauss’s policy did not cover Respondent. The Appellate Division reversed, concluding that Amato was inapplicable to SUM coverage mandated by section 3420(f)(2) and defining “motor vehicle” for purposes of statutorily required SUM coverage as inclusive of police vehicles. The Court of Appeals reversed, holding (1) a police vehicle is not a “motor vehicle” covered by a SUM endorsement under section 3420(f)(2)(a); and (2) Amato remains binding precedent in this matter of statutory interpretation. View "Matter of State Farm Mut. Auto. Ins. Co. v. Fitzgerald" on Justia Law