Mecca v. Farmers Insurance Exchange

Summary

The Montana Supreme Court affirmed summary judgment for Farmers Insurance Exchange in an underinsured motorist coverage dispute. The court held that the policy’s coverage depended on whether the vehicle involved was underinsured, and the U-Haul truck was not underinsured because it had approximately $7 million in bodily injury liability coverage, exceeding the appellants’ damages. The court therefore concluded that Farmers’ underinsured motorist coverage did not apply.

Holdings

1. The policy's underinsured motorist coverage attached to the underinsured motor vehicle, not merely to an underinsured driver. Because the U-Haul truck was covered by approximately $7 million in bodily-injury liability insurance—an amount exceeding the appellants' damages—the truck was not an underinsured motor vehicle, and Farmers owed no underinsured motorist benefits.
2. Summary judgment was proper because the undisputed policy terms and insurance coverage established that the underinsured motorist policy did not apply as a matter of law.

Questions Presented

1. Whether the Farmers underinsured motorist policy applied when the vehicle involved in the accident had approximately $7 million in available bodily-injury liability coverage, even though the driver had limited personal insurance coverage.

Disposition

affirmed