Summary
The Supreme Court of Ohio held that courts must consider the context of an insurance-policy provision within the policy as a whole when determining whether the provision is ambiguous. Applying that rule, the court concluded that a commercial general-liability policy unambiguously classified a flatbed trailer designed for travel on public roads as an excluded auto rather than covered mobile equipment. The court reversed the judgment of the court of appeals and remanded the case.
Topics
Practice areas
Questions Presented
- Whether ambiguity in an insurance-policy provision must be determined by examining the provision in the context of the policy as a whole.
- Whether the CGL policy's definitions unambiguously classified the flatbed trailer as an auto excluded from coverage rather than as mobile equipment covered by the policy.
Holdings
- When determining whether an insurance-policy provision is ambiguous, a court must consider the context in which the provision is used, including the overall context of the policy.
- The CGL policy unambiguously excluded the flatbed trailer from coverage because a trailer designed for travel on public roads is an auto under the policy, and the trailer did not qualify as mobile equipment under the policy's contextual definition.
Key quotations
“We accordingly hold that in determining whether an insurance policy provision is ambiguous, a court must consider the context in which the provision is used.” (¶ 14)
“When interpreting a provision in an insurance policy, courts must look at the provision in the overall context of the policy in determining whether the provision is ambiguous.” (¶ 25)
Factual background
A vehicle driven by Julia S. Augenstein collided with a flatbed trailer owned by Stinson J. Crews and Stinson Crews Trucking while the trailer was parked in a no-parking zone during paving work. Augenstein died from injuries sustained in the collision. The executors of her estate obtained a $251,552.04 negligence judgment against Crews. Crews sought coverage under a commercial general-liability policy issued by Century, which excluded autos but defined an auto to include trailers designed for travel on public roads, subject to an exception for mobile equipment.
Procedural history
After a vehicle collided with a flatbed trailer owned by Crews, the executors of the decedent's estate sued Crews and others for survivorship and wrongful death. Crews filed a third-party declaratory-judgment action against Century seeking coverage under a CGL policy, while Century sought a declaration that the policy excluded coverage. The trial court found Crews solely liable for the accident and later ruled on the coverage issue in favor of Crews; the Tenth District affirmed. The Supreme Court of Ohio reversed and remanded.
Remand instructions
Remanded to the court of common pleas for proceedings consistent with the opinion.