Garrett v. State Farm Mut. Auto. Ins. Co.

CourtNew Mexico Court of Appeals
DecidedJune 10, 2025
DocketA-1-CA-41530
StatusUnpublished

This text of Garrett v. State Farm Mut. Auto. Ins. Co. (Garrett v. State Farm Mut. Auto. Ins. Co.) is published on Counsel Stack Legal Research, covering New Mexico Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Garrett v. State Farm Mut. Auto. Ins. Co., (N.M. Ct. App. 2025).

Opinion

This decision of the New Mexico Court of Appeals was not selected for publication in the New Mexico Appellate Reports. Refer to Rule 12-405 NMRA for restrictions on the citation of unpublished decisions. Electronic decisions may contain computer- generated errors or other deviations from the official version filed by the Court of Appeals.

IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

No. A-1-CA-41530

AARON GARRETT, Personal Representative of the Wrongful Death Estate of Steven P. Gerecke, Deceased,

Plaintiff-Appellant,

v.

STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY,

Defendant-Appellee,

and

JEREMIAH KING and CHRISTOPHER RODRIGUEZ,

Defendants.

APPEAL FROM THE DISTRICT COURT OF SANTA FE COUNTY Bryan P. Biedscheid, District Court Judge

Elias Law P.C. Michael C. Ross Albuquerque, NM

for Appellant.

Allen Law Firm, LLC Meena H. Allen Kerri L. Allensworth Albuquerque, NM

for Appellee. MEMORANDUM OPINION

DUFFY, Judge.

{1} Plaintiff, as personal representative of the Estate of Steven P. Gerecke, Jr., appeals the district court’s order granting summary judgment in favor of State Farm Mutual Automobile Insurance Company. Plaintiff contends that the district court erred in concluding that none of the Gereckes’ three uninsured/underinsured motorist (UM/UIM) policies with State Farm covered the shooting death of Steven Gerecke. Concluding that the undisputed facts fail to establish a sufficient causal nexus between the use of the vehicle and Mr. Gerecke’s death, see Britt v. Phoenix Indemnity Ins. Co., 1995- NMSC-075, 120 N.M. 813, 907 P.2d 994, we affirm.

BACKGROUND

{2} The parties do not dispute the relevant facts on appeal. On June 26, 2015, the Albuquerque Police Department responded to reports of shots fired at Mr. Gerecke’s house. Mr. Gerecke lived on Chihuahua Avenue with his wife, Venita Gerecke. Upon arrival, police found Mr. Gerecke deceased in his driveway. Police located a garage door opener sitting on Mrs. Gerecke’s Honda. Police discovered a black bag, tan purse, laptop, and personal items belonging to Mrs. Gerecke lying on the north east corner of Chihuahua Avenue and Witcher Avenue. Mrs. Gerecke reported to police that the items found on the street had been in her house when she went to sleep that night. Police also found bullet casings near the Gerecke residence.

{3} A neighbor of the Gereckes told police that around 2:00 a.m., he awoke and witnessed what appeared to be seven to ten subjects ranging from sixteen to twenty- one years old on foot, moving as a pack, toward his neighbor’s house. Ten minutes after seeing the group of teens, the neighbor heard gunshots. Another neighbor stated that she heard three gunshots and saw three male subjects run east on Witcher Avenue from Chihuahua Avenue and enter a dark colored mid-sized SUV. The vehicle was parked on Witcher Avenue.

{4} Police arrested six teens aged fourteen to seventeen and charged them with homicide in connection with the shooting death of Mr. Gerecke. One of the teens told police that he and his friends “all exited [a] stolen SUV and went to ‘mob,’” meaning “go in a big group and break into cars and houses.” The teens walked up and down the street checking door handles on vehicles with the intent of either stealing the vehicles or breaking into residences using garage door openers obtained from the vehicles. A detective reported that while “mobbing,” large groups of unknown subjects travel through a neighborhood and burglarize multiple vehicles and homes at a time.

{5} The Gereckes carried three State Farm polices providing UM/UIM coverage. The policies state:

We will pay for damages for: (1) bodily injury an insured is legally entitled to collect from the owner or driver of an uninsured motor vehicle. The bodily injury must be:

(a) sustained by an insured, and

(b) caused by an accident arising out of the operation, maintenance or use of an uninsured motor vehicle as a motor vehicle.

Plaintiff filed a complaint in district court on behalf of Mr. Gerecke’s estate seeking to recover UM/UIM benefits under the policies. Plaintiff claimed that the assailants were uninsured motorists who used a vehicle as an active accessory in the commission of their crimes.

{6} State Farm moved for summary judgment on the basis that Mr. Gerecke’s injuries “[were] not sufficiently related to the ownership, maintenance, or use of the vehicle to trigger UM coverage.” Plaintiff did not dispute State Farm’s statement of facts in his response. Plaintiff did, however, assert four additional facts that generally established that an officer interviewed two people who witnessed a vehicle fleeing the scene. One of the witnesses stated that the vehicle was parked outside of her house on Witcher Avenue, and she reported observing three males running and yelling “let’s go” prior to entering a dark colored mid-size SUV. The witness also stated that there appeared to be a driver waiting for the three males to enter the vehicle. After a hearing on the motion the district court granted State Farm’s motion. Plaintiff appeals.

DISCUSSION

{7} Because the facts are undisputed in this case, our review centers on whether the district court correctly applied the law to the facts. McKinley v. Interinsurance Exch. of the Auto. Club, 2022-NMCA-055, ¶ 8, 517 P.3d 937. “Summary judgment is proper if there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law.” Id. ¶ 7 (internal quotation marks and citation omitted). “We review a grant of summary judgment de novo, viewing the facts in a light most favorable to the nonmoving party and drawing all reasonable inferences in support of a trial on the merits.” Castro v. Jones Contractors, Inc., 2024-NMCA-014, ¶ 10, 541 P.3d 182. “At the summary judgment stage, if the moving party satisfies its initial burden to make a prima facie factual showing warranting summary judgment, the burden shifts to the non- movant to demonstrate the existence of specific evidentiary facts [that] would require trial on the merits.” McKinley, 2022-NMCA-055, ¶ 7 (internal quotation marks and citation omitted). “If the party opposing summary judgment adduces evidence regarding material disputed facts and/or reasonable inferences, summary judgment is inappropriate.” Id. However, “[w]hen no facts are in dispute and the undisputed facts lend themselves to only one conclusion, the issue may properly be decided as a matter of law.” Castro, 2024-NMCA-014, ¶ 10 (alteration, internal quotation marks, and citation omitted). {8} We understand Plaintiff to argue that the district court erred in granting summary judgment based on its application of the Britt factors to the undisputed facts. In Britt, 1995-NMSC-075, ¶¶ 15-16, the New Mexico Supreme Court adopted a three-part test to determine whether UM/UIM coverage is available for intentional conduct and the resulting harm arising out of the use of an uninsured vehicle. The test from Britt first requires consideration of “whether there is a sufficient causal nexus between the use of the uninsured vehicle and the resulting harm. Such a causal nexus requires that the vehicle be an active accessory in causing the injury.” Id. ¶ 15 (internal quotation marks and citation omitted). If there is a sufficient causal nexus, the court next considers “whether an act of independent significance broke the causal link between the use of the vehicle and the harm suffered.” Id.

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Related

Britt v. Phoenix Indemnity Insurance
907 P.2d 994 (New Mexico Supreme Court, 1995)
Barncastle v. American National Property & Casualty Companies
11 P.3d 1234 (New Mexico Court of Appeals, 2000)
Crespin v. Safeco Ins. Co. of Am.
429 P.3d 968 (New Mexico Court of Appeals, 2018)
Haygood v. USAA
2019 NMCA 074 (New Mexico Court of Appeals, 2019)
McKinley v. Interinsurance Exch. of the Auto. Club
517 P.3d 937 (New Mexico Court of Appeals, 2022)
Castro v. Jones Contractors, Inc.
541 P.3d 182 (New Mexico Court of Appeals, 2023)

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Bluebook (online)
Garrett v. State Farm Mut. Auto. Ins. Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/garrett-v-state-farm-mut-auto-ins-co-nmctapp-2025.