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

• Two plaintiffs, both primary Spanish speakers with limited English proficiency, were involved in separate car accidents with underinsured drivers. They each filed claims for uninsured and underinsured motorist (UM/UIM) benefits with their respective insurance companies, which were denied. The core issue in both cases was whether the insurance companies obtained valid rejections of UM/UIM coverage from the plaintiffs, given the forms for selecting or rejecting such coverage were provided in English (paras 2-6).

Procedural History

• District Court of Bernalillo County: Summary judgment in favor of the defendants, based on the conclusion that each insurance company obtained a valid rejection of UM/UIM coverage from the plaintiffs (paras 1, 3, 5).

Parties' Submissions

• Plaintiff Graciela Contreras: Argued that the district court erred by granting summary judgment based on the erroneous conclusion that a valid rejection of UM/UIM coverage was obtained, and also contended that her claims alleging violations of the Unfair Practices Act were improperly dismissed (para 1).
• Defendant Fred Loya Insurance Company: Contended that the requirements set forth in Jordan were met, thus the rejection of UM/UIM coverage was valid (paras 12-13).
• Plaintiff Maria Varela-Burciaga: Argued similarly against the summary judgment, contending that the English-language form did not constitute a meaningful offer of UM/UIM coverage, and thus she did not knowingly or intelligently act to reject this coverage (para 11).
• Defendant State Farm Mutual Automobile Insurance Company: Argued that they were not required by law to provide a rejection of UM/UIM coverage in Spanish (para 21).

Legal Issues

• Whether the district court erred in granting summary judgment based on its conclusion that the insurance companies obtained valid rejections of UM/UIM coverage from the plaintiffs (para 9).
• Whether providing otherwise valid English-language forms satisfied the insurers' burden to meaningfully offer UM/UIM coverage so that the plaintiffs could knowingly and intelligently act to reject it (para 16).
• Whether insurers are required to provide UM/UIM selection/rejection forms in an insured’s primary or preferred language (para 22).

Disposition

• In Contreras v. Fred Loya Insurance Co., the Court of Appeals reversed the district court’s grant of summary judgment on Contreras’s declaratory judgment and breach of contract claims and vacated the grant of summary judgment on Contreras’s remaining claims (para 25).
• In Varela-Burciaga v. State Farm Mutual Automobile Insurance Co., the Court of Appeals affirmed the district court's decision granting summary judgment in favor of State Farm (para 25).

Reasons

• The Court of Appeals found that the district court erred in Contreras's case by concluding that a valid rejection of UM/UIM coverage was obtained simply because the rejection complied with the requirements set forth in Jordan, given Contreras's limited English proficiency and the lack of meaningful communication about the coverage in a language she could understand (paras 14-19). However, in Varela-Burciaga's case, the Court held that the law does not require insurers to provide UM/UIM selection/rejection forms in an insured’s primary or preferred language, and thus State Farm was not required to provide a Spanish-language form to Varela-Burciaga (paras 21-24).