Corriveau v. State Farm Mutual Automobile Insurance Company

Summary

The Supreme Court of Virginia affirmed the dismissal of a declaratory judgment action seeking uninsured motorist coverage for injuries sustained during assaults on a school bus. The Court held that the injuries did not arise out of the ownership, maintenance, or use of the bus as a vehicle because the bus served only as the situs of the assaults. The Court also overruled State Farm Mutual Automobile Insurance Co. v. Rice to the extent it was inconsistent with the governing causal-connection analysis.

Holdings

1. The injuries did not arise out of the ownership, maintenance, or use of the school bus as a vehicle because the bus served only as the situs or enclosure for the assaults, and there was no causal connection between the assaults and the bus's use as a means of transportation.
2. The special-needs harnesses did not create a sufficient causal nexus between the assaults and the use of the school bus because the assaults could have occurred without the restraints.
3. State Farm Mut. Auto. Ins. Co. v. Rice was overruled to the extent it was inconsistent with the categories recognized in Powell and the subsequent Virginia case law governing whether an injury arises out of the use of a vehicle.

Questions Presented

1. Whether Corriveau's injuries arose out of the use of the school bus as a means of transportation under the uninsured motorist provision of the State Farm policy.
2. Whether the special-needs harnesses supplied the causal nexus between Corriveau's injuries and the use of the school bus.
3. Whether State Farm Mutual Auto. Ins. Co. v. Rice remained controlling or should be overruled to the extent inconsistent with Virginia's developed vehicle-use coverage principles.

Disposition

affirmed