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

• A passenger was severely injured in a single-vehicle accident where the driver lost control and crashed. The driver was insured by State Farm with liability and uninsured/underinsured motorist (UM/UIM) coverage, both set at $250,000, with a contractual offset provision. The passenger, through his parents, was insured by Farmers with $90,000 in UM/UIM coverage through three stacked policies. After the accident, State Farm paid its liability policy limit of $250,000 to the passenger, and an additional $90,000 in UIM coverage, then sought a declaratory judgment against Farmers regarding the UIM coverage and offsets (paras 2-3).

Procedural History

• District Court of Bernalillo County, Alan M. Malott, District Judge: Granted summary judgment in favor of Farmers Insurance, determining that under Samora v. State Farm, Farmers owed no UIM benefits to the passenger due to the offset by State Farm’s liability payment (para 4).

Parties' Submissions

• Plaintiff (State Farm): Argued it was entitled to contractual and statutory offsets for its $250,000 liability payment and that Farmers should reimburse State Farm for the $90,000 UIM payment made to the passenger (para 4).
• Defendant (Farmers): Contended that its $90,000 in UIM coverage was fully offset by State Farm’s $250,000 liability payment, owing no UIM benefits to the passenger, as per Samora v. State Farm (para 4).

Legal Issues

• Whether State Farm is entitled to contractual and statutory offsets for its liability payment, requiring Farmers to reimburse State Farm for the UIM payment made to the passenger.
• Whether Farmers owes any UIM benefits to the passenger after the offsets applied by State Farm’s liability payment (para 4).

Disposition

• The Court of Appeals affirmed the district court’s decision, granting summary judgment in favor of Farmers, determining that Farmers owed no UIM benefits to the passenger (para 10).

Reasons

• Per Megan P. Duffy, J. (Julie J. Vargas, J., and Zachary A. Ives, J., concurring): The court found that the contractual offset in State Farm’s policy was enforceable, fully offsetting any UIM coverage due to the liability payment made to the passenger. Consequently, the passenger’s only UIM coverage was under his Farmers policy, totaling $90,000. Applying statutory offsets as per Samora and Safeco, the passenger’s UIM coverage did not exceed the liability coverage from State Farm, rendering the driver not underinsured and the passenger not entitled to any UIM benefits from Farmers. The court’s analysis was guided by precedent in Samora and Safeco, which provided clear instructions on applying statutory and contractual offsets in determining UIM claims (paras 5-9).