Purvis v. Progressive Casualty Insurance Co., 142 Idaho 213

Summary

The Idaho Supreme Court affirmed summary judgment for Progressive Casualty Insurance Company and Rossi Insurance Company in an insurance coverage dispute arising from an accident involving a rental car driven by the insured's minor daughter. The court held that the policy was an unambiguous owner's policy, excluded coverage for the rental vehicle and daughter under the relevant policy provisions, and satisfied Idaho's motor vehicle financial responsibility law.

Holdings

1. The Progressive policy was unambiguous when its provisions were read in context.
2. The policy excluded coverage for the rental vehicle and for Purvis's daughter while she was driving that vehicle.
3. The Progressive policy was an owner's policy that satisfied the minimum coverage requirements of Idaho Code section 49-1212(1). Its additional coverage for Purvis while driving certain nonowned automobiles did not convert it into an operator's policy or subject it to the requirements of section 49-1212(2).

Questions Presented

1. Whether the Progressive policy was ambiguous regarding whether it provided owner's-policy or operator's-policy coverage.
2. Whether the policy's exclusion of the rental vehicle and the daughter's use of it was enforceable.
3. Whether the policy complied with Idaho Code section 49-1212's minimum financial-responsibility requirements.
4. Whether the district court properly granted summary judgment to the insurers.

Disposition

affirmed