Danny J. Dobbins and Jackie L. Dobbins v. West Virginia National Auto Insurance Company

CourtWest Virginia Supreme Court
DecidedMay 21, 2026
Docket24-362
StatusPublished

This text of Danny J. Dobbins and Jackie L. Dobbins v. West Virginia National Auto Insurance Company (Danny J. Dobbins and Jackie L. Dobbins v. West Virginia National Auto Insurance Company) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Danny J. Dobbins and Jackie L. Dobbins v. West Virginia National Auto Insurance Company, (W. Va. 2026).

Opinion

IN THE SUPREME COURT OF APPEALS OF WEST VIRGINIA

January 2026 Term FILED _______________ May 21, 2026 released at 3:00 p.m. No. 24-362 C. CASEY FORBES, CLERK _______________ SUPREME COURT OF APPEALS OF WEST VIRGINIA

DANNY J. DOBBINS and JACKIE L. DOBBINS, Petitioners/Plaintiffs Below,

v.

WEST VIRGINIA NATIONAL AUTO INSURANCE COMPANY, Respondent/Defendant Below.

________________________________________________________

Appeal from the Intermediate Court of Appeals No. 23-ICA-101 (Circuit Court of Logan County No. 20-C-98)

REVERSED AND REMANDED ________________________________________________________

Submitted: April 22, 2026 Filed: May 21, 2026

Matthew M. Hatfield, Esq. Trevor K. Taylor, Esq. Madison, West Virginia Taylor Law Office Counsel for Petitioners Morgantown, West Virginia Counsel for Respondent

JUSTICE TRUMP delivered the Opinion of the Court. SYLLABUS BY THE COURT

1. “On appeal of a decision from the Intermediate Court of Appeals of

West Virginia, the Supreme Court of Appeals of West Virginia applies a de novo standard

of appellate review to a circuit court’s entry of summary judgment.” Syllabus Point 1,

Moorhead v. West Virginia Army National Guard, 251 W. Va. 600, 915 S.E.2d 378 (2025).

2. “Determination of the proper coverage of an insurance contract when

the facts are not in dispute is a question of law.” Syllabus Point 1, Tennant v. Smallwood,

211 W. Va. 703, 568 S.E.2d 10 (2002).

3. “Where the provisions of an insurance policy contract are clear and

unambiguous they are not subject to judicial construction or interpretation, but full effect

will be given to the plain meaning intended.” Syllabus, Keffer v. Prudential Insurance

Company of America, 153 W. Va. 813, 172 S.E.2d 714 (1970).

i TRUMP, Justice:

After Petitioner Danny J. Dobbins’ pick-up truck was hit by another vehicle

that fled the scene, Mr. Dobbins and Petitioner Jackie L. Dobbins, his wife, made a claim

for uninsured motorist (UM) coverage under Mrs. Dobbins’ automobile insurance policy.

The insurance company, Respondent West Virginia National Automobile Insurance

Company, denied coverage because petitioners had failed to report the accident to a police,

peace, or judicial officer within twenty-four hours. The insurance policy, however, clearly

and unambiguously provides that the failure to timely report the accident operates as a bar

to coverage only if the failure to report is prejudicial to West Virginia National. For this

reason, the Circuit Court of Logan County did not err in requiring West Virginia National

to prove that its investigative interests were prejudiced by petitioners’ failure to strictly

adhere to the twenty-four-hour reporting requirement and in finding that West Virginia

National failed to prove any such prejudice. Therefore, we reverse the decision of the

Intermediate Court of Appeals (ICA) finding that the circuit court erred in conducting a 1 prejudice analysis, and we remand this case for further proceedings.

I. Facts and Procedural History

On December 20, 2018, West Virginia National issued a Personal

Automobile Insurance Policy (Policy No. 1186521) to Mrs. Dobbins, under which policy

her husband, Mr. Dobbins, was a rated driver, and their 2001 Dodge Dakota pick-up truck

1 See West Va. Nat’l Auto Ins. Co. v. Dobbins, 249 W. Va. 681, 900 S.E.2d 730 (W. Va. Ct. App. 2023).

1 was an insured vehicle. The subject policy provided UM coverage for bodily injury in the

amount of $25,000/$50,000 and UM property damage coverage in the amount of $25,000

(less a $300 deductible).

On the afternoon of Friday, February 15, 2019, at approximately 3:30 p.m.,

Mr. Dobbins was operating the pick-up truck at or near Loraine Street in Logan, West

Virginia, when the truck was struck on the rear passenger side by another vehicle, a black

Toyota truck. Petitioners allege that the collision was caused by the driver of the Toyota

truck’s failure to maintain control of that vehicle and that the driver—who was (and

remains) unknown—fled the scene.

As to an insured’s claim for UM coverage where an unknown driver is

involved, West Virginia Code § 33-6-31(e) provides, in part:

(e) If the owner or operator of any motor vehicle which causes bodily injury or property damage to the insured is unknown, the insured, or someone in his or her behalf, in order for the insured to recover under the uninsured motorist endorsement or provision, shall:

(1) Within twenty-four hours after the insured discover, and being physically able to report the occurrence of such accident, the insured, or someone in his or her behalf, reports the accident to a police, peace or to a judicial officer, unless the accident has already been investigated by a police officer[.]

The subject policy provided, in pertinent part, as follows:

PART E – DUTIES AFTER AN ACCIDENT OR LOSS

We have no duty to provide coverage under this policy if the failure to comply with the following duties is prejudicial to us:

A. We must be notified promptly of how, when and where the accident or loss happened. Notice should also include the

2 names and addresses of any injured persons and of any witnesses.

B. A person seeking any coverage must: 1. Cooperate with us in the investigation, settlement or defense of any claim or suit. 2. Promptly send us copies of any notices or legal papers received in connection with the accident or loss. 3. Submit, as often as we reasonably require: a. To physical exams by physicians we select. We will pay for these exams. b. To examination under oath and subscribe the same. 4. Authorize us to obtain: a. Medical reports; and b. Other pertinent records. 5. Submit a proof of loss when required by us.

C. A person seeking Uninsured Motorists Coverage must also: 1. Within twenty-four hours after the insured discovers, and bring [sic] physically able to report the occurrence of such accident, the insured or someone in his or her behalf, reports the accident to a police, peace or to a judicial officer, unless the accident 2 has already been investigated by a police officer. 2. Promptly send us copies of the legal papers if a suit is brought.

(Footnote added).

2 Originally, subsection C.1 provided as follows:

C. A person seeking Uninsured Motorists Coverage must also:

1. Promptly notify the police if a hit-and-run driver is involved.

West Virginia National subsequently amended subsection C.1 by endorsement to the version in effect at the time of petitioners’ accident. According to West Virginia National, the purpose of the amendment was to track the language of West Virginia Code § 33-6- 31(e)(1). See infra.

3 After the accident, Mr. Dobbins drove the vehicle home. Although Mrs.

Dobbins later described Mr. Dobbins as being “upset” and “confused,” and Mr. Dobbins

complained of having injuries to his neck and back, neither he nor Mrs. Dobbins was

physically unable to report the accident to a police, peace, or judicial officer within twenty- 3 four hours.

According to petitioners, they did not report the accident to police within

twenty-four hours because it occurred toward the end of the business day on Friday,

February 15, 2019, and the following Monday, February 18, was a legal holiday 4 (President’s Day). Petitioners testified that several days after the accident, they went to

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Danny J. Dobbins and Jackie L. Dobbins v. West Virginia National Auto Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/danny-j-dobbins-and-jackie-l-dobbins-v-west-virginia-national-auto-wva-2026.