AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The plaintiff, Betty E. Ullman, representing herself and others similarly situated, initiated a class action lawsuit against Safeway Insurance Company. The lawsuit challenged the legality of Safeway's insurance documents, particularly focusing on whether the company obtained valid waivers of uninsured and underinsured motorist (UM/UIM) coverage, including stacked coverage, from its insureds. Ullman contended that Safeway's documentation was legally inadequate, affecting all policyholders in the class (paras 3, 27-31).

Procedural History

• Interlocutory appeal from the District Court of Santa Fe County: The district court denied Safeway Insurance Company's motion for summary judgment seeking dismissal of class action claims (para 1).
• Certiorari Granted, August 24, 2017, No. S-1-SC-36580. Released for Publication November 7, 2017.

Parties' Submissions

• Plaintiff: Argued that Safeway's uniform documentary language failed to comply with New Mexico law, particularly in offering and obtaining waivers of UM/UIM coverage, including stacked coverage. The plaintiff also contended that the particular circumstances surrounding an ultimate rejection, including the means in which the rejection was obtained, were immaterial (paras 27-31).
• Defendant (Safeway Insurance Company): Sought to prove that its insurance documents were legally adequate to support its rejections of claims of class members to UM/UIM benefits. Safeway asked the Court to rule that it obtained valid rejections of UM/UIM coverage in compliance with New Mexico law, reverse the order denying Safeway’s class-related motion for summary judgment, and remand with instructions to dismiss the class claims with prejudice and de-certify the class (paras 2, 32-38).

Legal Issues

• Whether Safeway Insurance Company obtained valid rejections of UM/UIM coverage in compliance with New Mexico law.
• Whether the district court's denial of Safeway's motion for summary judgment was appropriate, given the legal adequacy of Safeway's insurance documents concerning UM/UIM coverage, including stacked coverage (paras 1-2, 57-58).

Disposition

• The Court held that Safeway obtained valid rejections of UM/UIM coverage in compliance with New Mexico law and reversed the district court's determination to the contrary. The case was remanded to the district court for further proceedings as may be required (para 59).

Reasons

• The Court found that Safeway's forms complied with New Mexico law in all respects required for a valid rejection of UM/UIM coverage, including stacking. It determined that the district court erred in its ruling against Safeway on the controlling issue of law regarding the legal adequacy of Safeway's uniform documentation in obtaining waivers of UM/UIM coverage. The Court's analysis focused on the legal requirements for offering and obtaining waivers of UM/UIM coverage, the provision of premium costs corresponding to all available levels of coverage, and the process for rejecting UM/UIM coverage. The Court concluded that Safeway's documentation was legally adequate and met the statutory and regulatory requirements, thereby addressing the commonality and predominance of issues for class certification as determined by the district court (paras 39-58).