Mendenhall v. Mountain West Farm Bureau Mutual Insurance Co.

Summary

The Supreme Court of Wyoming affirmed summary judgment for Mountain West Farm Bureau Mutual Insurance Company in a declaratory judgment action concerning coverage for a vehicle involved in an accident. The court held that ownership of the vehicle passed through an inter vivos gift despite the certificate of title and registration remaining in the donor's name. Because Wyoming Electric no longer owned the vehicle at the time of the accident, the vehicle was not covered under Wyoming Electric's Mountain West insurance policy.

Holdings

1. An inter vivos gift can overcome the certificate-of-title presumption of vehicle ownership. Under the undisputed facts, Nelson's present donative intent, delivery of the truck, divestiture of dominion and control, and Lucas's acceptance completed the gift before the accident, even though title had not yet been transferred.
2. Mountain West was not obligated to cover Mendenhall's injuries because Wyoming Electric no longer owned the truck on the date of the accident, and the truck was therefore no longer covered under Wyoming Electric's policy.
3. Summary judgment for Mountain West was proper because the material facts were stipulated or undisputed and those facts established that ownership had passed by inter vivos gift before the accident.

Questions Presented

1. Whether ownership of the truck passed from Wyoming Electric to Lucas through an inter vivos gift before the accident despite the certificate of title remaining in Wyoming Electric's name.
2. Whether Mountain West was obligated to provide coverage under Wyoming Electric's insurance policy.
3. Whether the district court properly granted summary judgment to Mountain West.

Disposition

affirmed