Ka Ying Vue v. State Farm Insurance Companies

582 N.W.2d 264, 1998 Minn. LEXIS 559, 1998 WL 461252
CourtSupreme Court of Minnesota
DecidedAugust 6, 1998
DocketC1-97-632
StatusPublished
Cited by19 cases

This text of 582 N.W.2d 264 (Ka Ying Vue v. State Farm Insurance Companies) is published on Counsel Stack Legal Research, covering Supreme Court of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ka Ying Vue v. State Farm Insurance Companies, 582 N.W.2d 264, 1998 Minn. LEXIS 559, 1998 WL 461252 (Mich. 1998).

Opinion

OPINION

GARDEBRING, Justice.

In this case, ah automobile insurer challenges the presumption, created by statute and case law, that the person named on an automobile title as buyer is the vehicle’s owner. Instead, the insurer, relying on the theories. of joint ownership arising out of marital dissolution laws, asks us to establish a presumption that the spouse of the individual named on the vehicle title is also an owner. Because we find no basis in the Minnesota *265 No-Fault Act or in our previous cases for such a position, we reject the insurer’s claim and affirm the court of appeals.

Respondent Ka Ying Vue was a passenger in a 1985 Buick Skylark driven by her husband Ker Vang on January 22, 1996, when the car was involved in a collision with an uninsured stolen motor vehicle. 1 The Buick Skylark title named only Vang as the buyer of the vehicle; it was not insured at the time of the collision. However, appellant State Farm Insurance Companies (“State Farm”) had issued an insurance policy covering Vang’s other vehicle, a 1979 Chevrolet van, and Vue was an additional insured under that policy. Vue filed suit against State Farm, claiming uninsured motorist benefits under the State Farm policy covering the Chevrolet van, based on the uninsured status of the stolen vehicle.

State Farm filed a motion for summary judgment against Vue, claiming that Vue was not covered under the policy because she was occupying an owned but uninsured vehicle at the time of the accident. The district court granted State Farm’s motion for summary judgment, concluding that there was no coverage because: (1) the Buick Skylark was not an “uninsured vehicle” under the policy, which excluded uninsured motorist coverage if the uninsured vehicle was one “[ojwned by or furnished or available for the regular use of you or any family member;” and (2) the Buick Skylark was a “family vehicle,” and therefore the exclusion for injury “to any insured while occupying a motor vehicle owned or leased by the insured if it is not insured for uninsured motor vehicle coverage” was applicable to Vue’s claim.

On appeal, the court of appeals reversed. See Vue v. State Farm Ins. Companies, 568 N.W.2d 527 (Minn.App.1997). The court held that Vang, who held legal title to the Buick Skylark, was the vehicle owner, and not Vue. Id. at 529. Since Vue was not an owner of the Buick Skylark, the court held that the exclusion for injury “to any insured while occupying a motor vehicle owned or leased by the insured” did not apply to Vue. Id. The court also held that, to the extent the trial court based its decision on the uninsured status of the Buick Skylark, the court erred in granting summary judgment, since the claim for coverage Was based on the uninsured status of the other vehicle involved in the collision, and not on the uninsured status of the Buick Skylark. Id. at fn. 8. State Farm now appeals.

On appeal from summary judgment, this court must determine whether there are any genuine issues of material fact and whether the trial court erred in its application of the law. Vesta, State Bank v. Independent State Bank, 518 N.W.2d 850, 853 (Minn.1994). Questions of statutory construction are questions of law, and thus subject to de novo review. Hibbing Educ. Ass’n v. Public Employment Relations Bd., 369 N.W.2d 527, 529 (Minn.1985). Interpretation of an insurance policy, and its application to the facts of the case, are likewise questions of law. Meister v. Western Nat’l Mut. Ins. Co., 479 N.W.2d 372, 376 (Minn.1992).

Although State Farm concedes that Vue has alleged facts sufficient to establish a prima facie case of coverage for uninsured motorist benefits, the insurer argues that Vue is nevertheless precluded from receiving benefits because of an exclusionary clause in the policy. 2 The policy on the Chevrolet van *266 provides that “there is no [uninsured motorist] coverage * * * for bodily injury to any insured while occupying a motor vehicle owned or leased by the insured if it is not insured for uninsured motor vehicle coverage.” State Farm argues that Vue is a co-owner of the Buick Skylark that she was occupying at the time of the accident and was therefore “occupying a motor vehicle owned or leased by the insured.” Thus, it is State Farm’s position that she is barred from recovering uninsured motorist benefits under the policy.

Both parties agree that the sole issue on review is whether Vue is an owner of the uninsured Buick Skylark. If Vue is an owner, the exclusionary clause would apply to preclude coverage for her injuries; if Vue is not an owner, then the exclusionary clause would not apply and Vue would be entitled to receive uninsured motorist benefits as an “insured” under her husband’s policy on the Chevrolet .van. 3

The State Farm policy does not define the “owner” of a motor vehicle. However, the legislature has provided guidance on this issue. The Minnesota No-Fault Automobile Insurance Act, Minn.Stat. §§ 65B.41-.71 (1996) (hereinafter, “No-Fault Act”) defines an “owner” of a motor vehicle as “a person, other than a lienholder or secured party, who owns or holds legal title to a motor vehicle or is entitled to the use and possession of a motor vehicle.” Minn.Stat. § 65B.43, subd. 4. Vue’s husband Vang is listed on the title as the sole buyer of the vehicle. This court has previously established that the certificate of title creates a rebuttable presumption of ownership for purposes of both the No-Fault Act and the Motor Vehicle Certificate of Title Act, Minn.Stat. eh. 168A (1996). Arneson v. Integrity Mut Ins. Co., 344 N.W.2d 617, 618 (Minn.1984). We have also made clear that a party may introduce extrinsic evidence to rebut the presumption and prove that someone else actually owns the vehicle in question. Id.

State Farm, however, argues that as the spouse of the owner named on the title, Vue is a presumptive co-owner of the vehicle. To support its argument, State Farm points to the statutory presumption in marital dissolution that any property acquired during a marriage “by the parties * * * to a dissolution, legal separation, or annulment” is presumed to be marital property “regardless of whether title is held individually or by the spouses in a form of coownership.” Minn. Stat. § 518.54, subd. 5 (1996). State Farm argues that the same deference accorded to the marital relationship in the context of property division for dissolution purposes should be constructively applied to the marital relationship in the context of motor vehicle insurance.

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Cite This Page — Counsel Stack

Bluebook (online)
582 N.W.2d 264, 1998 Minn. LEXIS 559, 1998 WL 461252, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ka-ying-vue-v-state-farm-insurance-companies-minn-1998.