State Farm Mutual Automobile Insurance Co. v. Elmore

Summary

The Illinois Appellate Court, Fifth District, considered whether a State Farm automobile insurance policy's undefined "mechanical device" exclusion barred coverage for injuries sustained while the insured truck was used to unload grain through an auger. The court held that the exclusion was ambiguous and unenforceable as applied, reversed the circuit court's summary judgment for State Farm, and entered judgment for the defendants.

Holdings

1. The mechanical-device exclusion was overly broad, vague, and ambiguous because the policy did not clearly identify which devices used in loading and unloading would trigger the exclusion.
2. The mechanical-device exclusion must be construed against State Farm and in favor of coverage.
3. The circuit court's summary judgment for State Farm was reversed, and summary judgment was entered for Kent Elmore.

Questions Presented

1. Whether the policy's undefined mechanical-device exclusion was ambiguous as applied to an auger used to unload grain from the insured farm truck.
2. Whether the mechanical-device exclusion barred coverage for Kent Elmore's injuries under the State Farm policy.
3. Whether summary judgment should be entered for State Farm or Kent.

Disposition

reversed