Pease v. State Farm Mutual Automobile Insurance

SILVER, J.,

concurring.

[¶ 12] I concur in the result but not in the reasoning of the Court. The Court very narrowly interprets the State Farm policy in order to avoid a conflict with the uninsured motorist statute. I would find that the “regular use” exclusion violates the uninsured motorist statute. I also write to point out that Lincoln County did not provide UM coverage to Officer Pease.

[¶ 13] “The purpose of section 2902 is to permit an insured injured person the same recovery which would have been available to [him or] her had the tortfeasor been insured to the same extent as the injured party.” Skidgell v. Universal Underwriters Ins. Co., 1997 ME 149, ¶ 8, 697 A.2d 831, 833. The statute does not refer to exclusions at all, and we have said that we will not sanction reductions in coverage for which the Legislature has not provided. See id. ¶ 9, 697 A.2d at 834. Thus, even if the exclusionary language in State Farm’s policy is explicit and unambiguous, it cannot prevail if it is contrary to the UM statute or public policy. See id. ¶ 7, 697 A.2d at 833.

[¶ 14] In accordance with these principles, we have never upheld any other exclusion to UM coverage outside some variation on the owned-uninsured exception, despite State Farm’s suggestions to the contrary. Quite the opposite, Maine courts have repeatedly held that insurers may not limit UM coverage by adding restrictive language to their UM policies. Policy exclusions have thus been invalidated if they restrict the right of an insured to recover damages under the UM statute. See, e.g., Butterfield v. Norfolk & Dedham Mut. Fire Ins. Co., 2004 ME 124, ¶ 2, 860 A.2d 861, 862 (holding that an insurer may not restrict UM coverage to claims brought by named insureds for only those injuries sustained by named insureds, as opposed to any individual for whom a *1077named insured is legally entitled to bring a claim); Skidgell, 1997 ME 149, ¶ 6, 697 A.2d at 833 (providing that an insurance company cannot limit UM coverage to passengers in a car, as opposed to a motorcycle); Young v. Greater Portland Transit Dist., 535 A.2d 417, 420 (Me.1987) (invalidating the governmental vehicle exclusion because the statute mandates coverage for all uninsured motorists, without differentiating between financially responsible and financially irresponsible drivers); Dufour v. Metro. Prop. & Liab. Ins. Co., 438 A.2d 1290, 1291 (Me.1982) (recognizing that a pedestrian may recover damages under her UM coverage for injuries caused by the negligence of an uninsured motorist); Wescott v. Allstate Ins., 397 A.2d 156, 167-70 (Me.1979) (finding that the no-consent-to-settlement and excess-escape exclusionary clauses were void as against public policy and in contravention of the uninsured motorist statute); Murphy v. Allstate Ins. Co., 2003 WL 1618565, 2003 Me.Super. Lexis 18 (Jan. 27, 2003) (holding that the UM statute permits recovery for injuries sustained while riding a bicycle).

[¶ 15] Judicial decisions in several states hold that a regular use exclusion in UM coverage is invalid because UM coverage is “portable under all circumstances.” Blazekovic v. City of Milwaukee, 234 Wis.2d 587, 610 N.W.2d 467, 471 (2000) (quotation marks omitted); see also Niemann v. Badger Mut. Ins. Co., 143 Wis.2d 73, 420 N.W.2d 378, 381 (Ct.App.1988). Viewing UM coverage as “limited personal accident insurance,” these courts emphasize that UM coveragé is available “at all times and under all circumstances when a named insured sustains injury caused by accident as a result of an uninsured automobile.” Bilbrey v. Am. Auto. Ins. Co., 495 S.W.2d 375, 376 (Tex.Civ.App.1973). Unlike liability coverage, UM coverage “inures to the person, not the vehicle.” Gibbs v. Nat’l Gen. Ins. Co., 938 S.W.2d 600, 606 (Mo.Ct.App.1997).

[¶ 16] Such reasoning comports with the policy and purpose of Maine’s UM statute. Maine precedent has ensured that UM coverage extends to pedestrians, bicyclists, and other insured who are injured while not in their owned-insured vehicle. Construing the UM statute broadly to prohibit such exclusions follows the legislative intent to close coverage gaps rather than endorse patchwork policies that leave responsible, insured consumers without the protection they have paid for. As the majority notes, “[t]he legislative intent is to benefit all insured motorists by throwing the burden of compensating for injuries which would otherwise go without redress from the individual victim to the insurance industry for a premium.” Wes-cott, 397 A.2d at 166.

[¶ 17] If Lincoln County were able to provide UM coverage to on-duty officers, it is unlikely that Pease’s claim would ever have reached this Court. It is important to note that many law enforcement officers do not have UM coverage on their patrol vehicles. Therefore, they are denied traditional personal injury protections when involved in an automobile accident with an underinsured driver.