Kimberly Rogers v. Erie Insurance Exchange

CourtCourt of Appeals of Kentucky
DecidedApril 18, 2024
Docket2023 CA 000447
StatusUnknown

This text of Kimberly Rogers v. Erie Insurance Exchange (Kimberly Rogers v. Erie Insurance Exchange) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kimberly Rogers v. Erie Insurance Exchange, (Ky. Ct. App. 2024).

Opinion

RENDERED: APRIL 19, 2024; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-0447-MR

KIMBERLY ROGERS APPELLANT

APPEAL FROM FAYETTE CIRCUIT COURT v. HONORABLE KIMBERLY N. BUNNELL, JUDGE ACTION NO. 22-CI-02508

ERIE INSURANCE EXCHANGE; ALLSTATE INSURANCE COMPANY; AND LYFT, INC. APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: CETRULO, LAMBERT, AND TAYLOR, JUDGES.

TAYLOR, JUDGE: Kimberly Rogers brings this appeal from an April 3, 2023,

judgment of the Fayette Circuit Court granting Lyft, Inc.’s motion for summary

judgment, Allstate Insurance Company’s motion for summary judgment, and Erie

Insurance Exchange’s motion for judgment on the pleadings. We affirm. On February 1, 2022, Kimberly Rogers was a driver for Lyft, Inc.

(Lyft) and was involved in an automobile accident with another motor vehicle.

Rogers apparently suffered substantial physical injuries. The driver of the other

motor vehicle negligently caused the accident and was insured by State Farm

Automobile Insurance Company (State Farm). State Farm paid Rogers the

policy’s liability coverage limits. At the time of the accident, Rogers’ vehicle was

insured by Erie Insurance Exchange (Erie), and Lyft carried motor vehicle

insurance with Allstate Insurance Company (Allstate). Both Erie and Allstate

denied Rogers’ claims for underinsured motorist (UIM) benefits.

As a result, Rogers filed a complaint in the Fayette Circuit Court

against Erie, Allstate, and Lyft. In the complaint, Rogers asserted:

FACTS

14. Defendant Lyft is required by 601 KAR [Kentucky Administrative Regulations] 1:113 § 3(1) to maintain primary automobile insurance that provides coverage bother [sic] for a driver who is logged into the Lyft application AND for drivers engaged in a prearranged ride.

15. Defendant Lyft is also required by 601 KAR 1:113 § 3(2) to maintain liability insurance, PIP [Personal Injury Protection] coverage, UM [Uninsured Motorist] coverage and UIM coverage for drivers who are logged into the Lyft application, who are not engaged in a prearranged ride.

16. Defendant Allstate insures Lyft under a policy of insurance that Defendant Allstate represents only

-2- provides the coverage required by KRS [Kentucky Revised Statutes] § 281.655(12) as a prearranged ride liability policy, which Allstate contends applies only when Plaintiff was carrying persons for Defendant Lyft.

17. Defendant Lyft either failed to maintain a policy that provided coverage for Plaintiff as required by KRS § 281.655(12) and 601 KAR 1:113 § 3, or Allstate misrepresented the scope of coverage afforded by its policy.

18. Defendant Erie insures Plaintiff under a policy which it contends excludes UIM coverage for all transportation network company activities, whether as part of a pre-trip liability policy or prearranged ride liability policy.

....

COUNT I KRS § 446.070 VIOLATION OF KRS § 281.655 Defendant Lyft

23. Defendant Lyft was required by KRS § 281.655 to maintain primary automobile insurance that complies with the requirements of 601 KAR 1:113 § 3.

24. Pursuant to the aforementioned statutes and regulations Defendant Lyft was required to maintain UIM insurance in the amount of $50,000 per person, $100,000 per accident.

25. Defendant Lyft has violated the aforementioned laws and regulations by failing to procure insurance of any kind that provided UIM coverage during the time period in which she was logged

-3- into Defendant Lyft’s application but was not engaged in the active transportation of a passenger.

COUNT II NEGLIGENCE PER SE Defendant Lyft

28. Defendant Lyft had a statutory duty to maintain UIM insurance to cover Plaintiff while she was logged into the Lyft application, even when not engaged in providing prearranged rides to Lyft customers.

29. Defendant Lyft breached this statutory duty when it failed to verify that primary insurance providing the required minimum insurance coverage to the Plaintiff was in place, either through Defendant Allstate or Defendant Erie.

COUNT III UIM Defendants Allstate and Erie

34. To the extent that Defendant Allstate is contractually obligated to provide UIM coverage to Lyft drivers engaged in Lyft operations in the Commonwealth of Kentucky, and to the extent that Plaintiff was engaged in Lyft operations in the Commonwealth of Kentucky, Defendant Allstate is required to provide UIM coverage to the Plaintiff in an amount of at least $50,000.

35. To the extent that it is determined that Plaintiff was not engaged in Defendant Lyft’s operations at the

-4- time of the collision that is the subject hereof, Defendant Erie is required to provide UIM coverage to Plaintiff, not to exceed the limits of Plaintiff’s policy with Defendant Erie.

August 31, 2022, Complaint at 3-7.

Lyft, Erie, and Allstate filed Answers. Eventually, Erie filed a motion

for judgment on the pleadings under Kentucky Rules of Civil Procedure (CR)

12.02 and CR 12.03. Erie pointed out that at the time of the accident, Rogers was

logged into Lyft’s mobile application. Under its insurance policy covering Rogers’

motor vehicle, Erie argued that UIM coverage was specifically excluded when a

motor vehicle was available for hire by the public. At the time of the accident,

Erie maintained that Rogers’ motor vehicle was available for hire by the public;

thus, UIM coverage was excluded under the clear policy provision. As UIM

coverage was excluded under its insurance policy, Erie sought dismissal of Rogers’

claim for UIM coverage. In her response, Rogers argued Erie was required to

provide UIM coverage as mandated per 601 KAR 1:113 Section 3.

Thereafter, Allstate filed a motion for summary judgment. Allstate

admitted it had issued Lyft a business automobile insurance policy that was in

effect at the time of Rogers’ accident. However, Allstate maintained that Lyft

rejected UIM coverage, and as a result, the insurance policy did not provide UIM

coverage. Consequently, Allstate sought summary judgment dismissing the claim

for UIM coverage.

-5- Lyft also filed a motion for summary judgment. Lyft stated that it

obtained automobile insurance coverage from Allstate in compliance with KRS

281.655 and 601 KAR 1:113. Lyft argued that neither KRS 281.655 nor 601 KAR

1:113 required it to obtain UIM coverage. Rather, Lyft maintained that UIM

coverage was optional per KRS 304.39-320(2).

Rogers filed a combined response to Allstate’s motion for summary

judgment and Lyft’s motion for summary judgment. Rogers attached her affidavit

to the response. In the affidavit, Rogers stated that at the time of the accident, she

was logged onto the “Lyft Application, . . . had accepted a ride, and was on my

way to pick up a passenger for Lyft.” Rogers’ Affidavit at 1. According to

Rogers, 601 KAR 1:113 Section 3(1) mandated that Lyft maintain the primary

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Kimberly Rogers v. Erie Insurance Exchange, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kimberly-rogers-v-erie-insurance-exchange-kyctapp-2024.