Haworth v. Jantzen

Summary

The Supreme Court of Oklahoma held that exclusions in an Oklahoma Farm Bureau farm and ranch insurance policy were ambiguous because they appeared to conflict regarding coverage for land motor vehicles. Construing the ambiguity against the insurer, the court upheld summary judgment providing coverage for the insured's personal liability arising from a pickup-truck accident on the insured premises. The court vacated the Court of Civil Appeals' opinion and remanded for consideration of unresolved issues concerning post-judgment interest, costs, and attorney fees.

Holdings

1. The policy exclusions were ambiguous because exclusions 1(b) and 1(c), read together, created conflicting and confusing possibilities concerning when coverage for injury arising from use of a land motor vehicle was excluded.
2. The ambiguous exclusions must be construed against Farm Bureau and in favor of the insured; therefore, the farm and ranch policy did not exclude coverage for Jantzen's personal liability arising from use of the pickup on the insured premises.
3. The trial court properly granted summary judgment because the material facts were undisputed and the coverage issue presented a question of law.
4. After vacating the Court of Civil Appeals opinion, the Supreme Court remanded the matter to that court to address the unresolved assignments of error concerning post-judgment interest, costs, and attorney fees.

Questions Presented

1. Whether the farm and ranch policy's motor-vehicle exclusions were ambiguous.
2. Whether the trial court properly construed the ambiguous exclusions against Farm Bureau and granted summary judgment providing coverage for the accident.
3. Whether the unresolved issues concerning post-judgment interest, costs, and attorney fees should be decided by the Oklahoma Supreme Court or remanded to the Court of Civil Appeals.

Disposition

vacated