County Hall Insurance Company, Inc. v. Jose Riveras; Riveras Trucking Inc.; and Ruben Story

District Court, D. Utah·Decided September 14, 2026·No. 2:25-cv-00971·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH

COUNTY HALL INSURANCE COMPANY, INC., MEMORANDUM DECISION AND ORDER Plaintiff, 2:25-cv-00971-RJS-JCB v. District Judge Robert J. Shelby JOSE RIVERAS; RIVERAS TRUCKING INC.; and RUBEN STORY Magistrate Judge Jared C. Bennett

Defendants.

Before the court are Plaintiff County Hall Insurance Company (County Hall)’s and Defendant Ruben Story’s Cross-Motions for Summary Judgment.1 For the reasons discussed below, the court GRANTS County Hall’s Motion and DENIES Story’s Motion. BACKGROUND2 This case arises from a collision between an automobile and a commercial truck. County Hall is a commercial auto liability insurance company.3 Defendant Jose Riveras is the sole

1 Dkt. 17, Defendant Story’s Motion for Summary Judgment (Story Motion); Dkt. 31, Plaintiff’s Cross-Motion for Summary Judgment (County Hall Motion). 2 When reviewing cross-motions for summary judgment, the court provides a neutral summary of the facts. See Stella v. Davis Cnty., 1:18-cv-002, 2019 WL 4601611, at *1 n.1 (D. Utah Sep. 23, 2019). The court views the facts “‘in the light most favorable to the nonmoving party’” and ‘draw[s] reasonable inferences therefrom’ while evaluating the motions in turn.” Id. (quoting Doe v. City of Albuquerque, 667 F.3d 1111, 1122 (10th Cir. 2012)). 3 Story Motion ¶ 3; Dkt. 37, Plaintiff’s Opposition to Defendant Story’s Motion for Summary Judgment (Story Opposition) at 5. owner of Defendant Riveras Trucking, Inc., a trucking corporation based in Taylorsville, Utah.4 Defendant Story is a judgment creditor of Jose Riveras and Riveras Trucking.5 I. Legal and Regulatory Framework In 1980, Congress passed the Motor Carrier Act (MCA) in an effort to deregulate the commercial trucking industry and improve quality of service.6 Out of concern that the loosened

regulatory environment could create public safety risks, Congress included provisions to increase liability protections for motor carriers.7 Specifically, the MCA requires motor carriers under its jurisdiction to register with the agency,8 and demonstrate it “is willing and able to comply with . . . . the minimum financial responsibility requirements established by the [Federal Motor Carrier Safety Administration (FMCSA)].”9 Pursuant to the statute, the FMCSA promulgated regulation requiring certain motor carriers to provide proof of financial responsibility.10 Carriers may satisfy this requirement by: (1) “Endorsement(s) for Motor Carrier Policies of Insurance for Public Liability Under Sections 29 and 30 of the Motor Carrier Act of 1980” (Form MCS–90) issued by an insurer(s); (2) A “Motor Carrier Surety Bond for Public Liability Under Section 30 of the Motor Carrier Act of 1980” (Form MCS–82) issued by a surety; or (3) A written decision, order, or authorization of the Federal Motor Carrier Safety Administration authorizing a motor carrier to self- insure under § 387.309, provided the motor carrier maintains a

4 Story Motion ¶ 2; Dkt. 17-1, Appendix of Evidence in Support of Defendant Story’s Motion for Summary Judgment (Story Exhibits) at 5‒6, Exhibit B (Articles of Incorporation for Riveras Trucking Inc.). 5 Dkt. 17-1, Exhibit O (Money Judgment in Favor of Plaintiff and Against Defendants Jose W. Rivera and Riveras Trucking, Inc.) (Default Judgment) at 68‒72. 6 Carolina Cas. Ins. Co. v. Yeates, 584 F.3d 868, 873 (10th Cir. 2009); see also Motor Carrier Act of 1980, Pub. L. No. 96-296, 94 Stat. 793 (1980). 7 Id. 8 49 U.S.C. § 13901(a). 9 Id. § 13902(a)(1)(A)(vi). 10 49 C.F.R. § 387.7(d). satisfactory safety rating as determined by the Federal Motor Carrier Safety Administration under part 385 of this chapter.11 This proof requirement only applies to “for-hire motor carriers operating motor vehicles transporting property in interstate or foreign commerce.”12 The MCS-90 endorsement “provides that the motor carrier's insurer ‘agrees to pay, within the limits of liability . . ., any final judgment recovered against the insured for public liability resulting from negligence in the operation, maintenance or use of motor vehicles subject to the financial responsibility requirements of ... the [MCA]’” regardless of whether the specific vehicle involved in the accident was included in the insurance policy.13 Accordingly, the MCS- 90 endorsement functions as a “safety net that covers the public in the event other insurance coverage is lacking.”14

Courts disagree about when the MCS-90 endorsement’s coverage is triggered. The majority of courts follow a trip-specific standard limiting coverage to “vehicles only when they are presently engaged in the transportation of property in interstate commerce.”15 Other courts have rejected the trip-specific approach and apply a general standard: coverage extends when a motor-carrier generally engages in for-hire transport of property in interstate or foreign

11 Id. 12 Id. § 387.3(a). 13 Herrod v. Wilshire Ins. Co., 499 Fed. App’x 753, 755 (10th Cir. 2012) (unpublished) (quoting 49 C.F.R. § 387.15). 14 Id. at 756 (quoting Yeates, 584 F.3d at 874). 15 Canal Ins. Co. v. Coleman, 625 F.3d 244, 249 (5th Cir. 2010); see also Nat’l Specialty Ins. Co. v. Martin-Vegue, 644 Fed. App’x. 900, 907 (11th Cir.) (applying the trip-specific approach); Century Indem. Co. v. Carlson, 133 F.3d 591, 599 (8th Cir. 2008) (requiring the hauled-product be in interstate commerce “at the time of the accident”); Herrod, 499 Fed. App’x at 760; Lyons v. Lancer Ins. Co., 681 F.3d 50, 57–60 (2d. Cir. 2010) (applying the trip- specific approach to determine whether an MCS-90B—an endorsement provided to passenger carriers which is identical to an MCS-90—covered an accident). commerce, regardless of the purpose of the specific trip during which an accident occurred.16 The Tenth Circuit has not issued a binding decision on this issue. II. The Collision On February 27, 2017, Riveras Trucking purchased a commercial auto insurance policy (the Policy) from County Hall.17 The Policy covered two vehicles: a 2010 Cascadia 125

Freightliner (VIN 1FUJGLDR9ASAK3580) and a 2004 Hyundai Steel Industries Trailer (VIN 3H3V532C44T151015).18 In addition to the Policy, County Hall issued Riveras Trucking an MCS-90 endorsement for $750,000.19 The endorsement includes the following statement: In consideration of the premium stated in the policy to which this endorsement is attached, the insurer (the company) agrees to pay, within the limits of liability described herein, any final judgment received against the insured for public liability resulting from negligence in the operation, maintenance or use of motor vehicles subject to the financial responsibility requirements of Sections 29 and 30 of the Motor Carrier Act of 1980 regardless of whether or not each motor vehicle is specifically described in the policy and whether or not such negligence occurs on any route or in any territory authorized to be served by the insured or elsewhere.20 On March 29, 2017, Riveras Trucking registered with the FMCSA as an interstate, for- hire, general freight motor carrier.21 Two days later, Riveras Trucking registered a 2009

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County Hall Insurance Company, Inc. v. Jose Riveras; Riveras Trucking Inc.; and Ruben Story, (D. Utah 2026).

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