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

• On December 26, 2015, the Hernandez Defendants committed a series of car burglaries, including at Mr. McKinley's residence. During their attempt to flee with stolen property, Mr. McKinley confronted them, resulting in a physical altercation inside their uninsured vehicle where one of the Hernandez Defendants fatally stabbed Mr. McKinley. Hernandez was later convicted for Mr. McKinley’s death (para 3).

Procedural History

• District Court of Bernalillo County: Granted summary judgment in favor of Defendants Interinsurance Exchange of the Automobile Club and Farmers Insurance Company of Arizona, dismissing Plaintiff's claim for uninsured/underinsured motorist (UM/UIM) coverage (para 1).

Parties' Submissions

• Plaintiff: Argued that the intentional stabbing of William McKinley should be covered under the UM/UIM policies because the vehicle was used to facilitate the harm, providing access to a deadly weapon and facilitating the attackers' escape (paras 11-15).
• Defendants: Contended that Mr. McKinley’s injuries did not arise from the “use” of an uninsured vehicle as required for UM/UIM coverage, emphasizing that the vehicle did not facilitate the harm and that an act of independent significance (the stabbing) broke any causal link (para 4).

Legal Issues

• Whether the district court correctly ruled that the intentional stabbing of William McKinley was not covered by the UM/UIM policies under the standard set forth in Britt v. Phoenix Indemnity Insurance Company (para 2).

Disposition

• The Court of Appeals affirmed the district court’s judgment dismissing Plaintiff’s claim for UM/UIM coverage (para 17).

Reasons

• The Court, per Judge Wray with Judges Ives and Henderson concurring, held that the stipulated facts did not demonstrate that the Hernandez Defendants used the vehicle to facilitate the harm to Mr. McKinley. The Court applied the three-part test from Britt, focusing on whether there was a sufficient causal connection between the use of the vehicle and the harm, whether an act of independent significance broke the causal link, and whether the use of the vehicle was a normal use. The Court found that the stabbing, an act of independent significance, broke any causal link between the use of the uninsured vehicle and the intentional harm. The Court concluded that the vehicle was not used to facilitate the attack, as there was no evidence suggesting that the Hernandez Defendants anticipated any attack using the vehicle or that the vehicle was used to access weapons or facilitate the attack in any way (paras 5-16).