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

• Plaintiffs, Angela and Joe Lueras, and David Van Epps, filed lawsuits against GEICO for refusing to pay uninsured/underinsured (UM/UIM) benefits, claiming they had rejected UM/UIM coverage. The Luerases had a policy for three vehicles, later adding a fourth, and rejected UM/UIM coverage on the forms provided by GEICO, which did not mention that UM/UIM benefits would be stacked. David Van Epps' wife initially selected UM/UIM coverage below the policy's liability limits, and after receiving a form from GEICO, rejected UM/UIM coverage for all their vehicles. Both parties' claims were based on the argument that the rejection forms and policies were misleading or violated New Mexico law.

Procedural History

• District Court of Bernalillo County: Summary judgment granted in favor of GEICO against the Luerases.
• District Court of Taos County: Summary judgment granted in favor of GEICO against David Van Epps.

Parties' Submissions

• Plaintiffs: Argued that the UM/UIM rejection forms violated New Mexico law by not explaining that UM/UIM benefits would be stacked and that the policies were misleading. The Luerases also claimed that GEICO's declaration page misrepresented the amount of UM/UIM coverage and that GEICO's policy of requiring the same level of UM/UIM insurance on each vehicle or rejecting it entirely violated New Mexico law. Mr. Van Epps contended that the form sent to his wife discouraged her from purchasing UM/UIM coverage, making her rejection invalid.
• Defendant-Appellee (GEICO): Defended the legality and clarity of their UM/UIM rejection forms and policies, arguing that their practices complied with New Mexico law and that the plaintiffs had validly rejected UM/UIM coverage.

Legal Issues

• Whether the UM/UIM rejection forms violated New Mexico law by not explaining that UM/UIM benefits would be stacked.
• Whether the insurance policies were misleading and ambiguous because they stated that UM/UIM benefits would not be stacked.
• Whether GEICO's requirement for plaintiffs to purchase the same level of UM/UIM insurance on each vehicle covered by a single policy or reject UM/UIM insurance entirely violated New Mexico law.
• Whether GEICO's failure to obtain another rejection of UM/UIM coverage when the Luerases added a vehicle to their policy entitled them to UM/UIM coverage.
• Whether the form sent to Mr. Van Epps' wife improperly discouraged her from purchasing UM/UIM coverage, rendering her rejection invalid.

Disposition

• The Court of Appeals affirmed the district courts' grants of summary judgment in favor of GEICO and denied the plaintiffs' cross-motions for summary judgment.

Reasons

• The Court of Appeals, per Judge Kiehne, held that the claims regarding the UM/UIM rejection forms and policies were controlled by precedent in Ullman v. Safeway Insurance Co., which had rejected similar claims. The court found no violation of New Mexico law in GEICO's practices, including the requirement to choose the same UM/UIM coverage for all vehicles or reject it entirely. The court also upheld that GEICO was not required to obtain a new rejection of UM/UIM coverage when a new vehicle was added to a policy, citing Vigil v. Rio Grande Insurance of Santa Fe. Finally, the court rejected Mr. Van Epps' claim about the form sent to his wife, stating that GEICO was required by law to send the UM/UIM coverage form and that nothing in it discouraged selecting UM/UIM coverage (paras 1-35).