Eleventh Circuit Court of Appeals
State Farm Mutual Automobile Insurance Company v. Spangler
11th Circuit Court of Appeals
4/3/23, Judge Jill Pryor
Topics: Negligence, Summary Judgment Standard
While driving, Mrs. Spangler’s car was struck by the uninsured driver of an electric motorized scooter, which resulted in injury to her. The Spanglers made a claim against State Farm under their car insurance policy’s uninsured motorist (“UM”) coverage.
State Farm denied coverage, taking the position that the scooter was neither a motor vehicle nor an uninsured motor vehicle nor a land motor vehicle.
State Farm took the step of filing a declaratory judgment action to confirm the lack of coverage. Both parties moved for summary judgment. The district court denied the Spanglers’ motion for summary judgment and granted partial summary to State Farm, holding that Florida’s statutory definition of a motor vehicle resolved the dispute in State Farm’s favor.
On appeal, the Spanglers argued that the definitions of uninsured motor vehicle and land motor vehicle in the policy trump the more defense-friendly language of the statute because the policy is a contract. The circuit court agreed, finding that the policy definition was broader and applied instead of statutory language.