Nicky Travieso v. Ciara Crespo

Supreme Court of New Jersey·Decided August 6, 2026·No. A-10-25·Published

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

Nicky Travieso v. Ciara Crespo (A-10-25) (091127)

Argued March 31, 2026 -- Decided August 6, 2026 JUSTICE PATTERSON, writing for a unanimous Court.

In this appeal, the Court considers the application of N.J.S.A. 17:28-1.1(f) to uninsured motorist (UM) coverage -- mandatory first-party coverage insuring against the possibility of injury or property damage caused by a driver without liability insurance coverage. Specifically, the Court considers whether plaintiff Nicky Travieso’s recovery under his employer’s automobile liability policy for an accident caused by an uninsured motorist while Travieso was driving his employer’s vehicle extends to the policy’s $1,000,000 third-party liability limit or is instead limited to $15,000 -- the UM coverage limit that his employer selected under the policy.

The vehicle Travieso was driving at the time of the accident was insured under a policy issued by defendant Zurich American Insurance Company (Zurich). The policy provided automobile liability coverage up to a limit of $1,000,000 and general liability coverage also up to a limit of $1,000,000. The policy offered options for UM and UIM (underinsured motorist) coverage limits ranging from the then-applicable statutory mandatory minimum of $15,000 upwards. Travieso’s employer purchased UM coverage subject to the $15,000 mandatory minimum.

In response to Travieso’s demand for UM coverage, Zurich offered him $15,000, the maximum UM coverage available under the policy. Travieso declined that offer and brought suit, contending that N.J.S.A. 17:28-1.1(f) mandated that Zurich provide UM coverage equal to the policy’s third-party liability limit of $1,000,000. The trial court ruled that “the maximum coverage available” for Travieso’s UM claim “should be a million dollars,” and ordered that the policy be reformed “to state that fact.” The court stated that “the business has a policy of a million dollars” in UM coverage for itself, but only $15,000 in UM coverage for its employees, which was “an attempt to circumvent the statute.”

The Appellate Division denied Zurich’s motion for leave to appeal. The Court granted leave to appeal, limited to arguments regarding the interpretation of N.J.S.A. 17:28-1.1(f). 262 N.J. 61 (2025).

HELD: Because the Legislature addressed UM coverage and UIM coverage in precisely the same way when it enacted N.J.S.A. 17:28-1.1(f), the Court’s interpretation of the statute in the UIM coverage setting of Chiaccheri v. Zurich American Insurance Co., ___ N.J. ___ (2026), decided today, also governs the UM coverage question raised in this appeal. Thus, the employer’s automobile liability policy at issue in this appeal entitles Travieso to UM coverage up to $15,000 -- the UM coverage limit that his employer selected under the policy -- not up to the policy’s $1,000,000 third-party liability limit.

1. The Zurich policy makes clear that the UM coverage provided to Travieso’s employer as the named insured and the UM coverage provided to employees such as Travieso were subject to the same $15,000 limit for an injury to or the death of one person, consistent with the limits then in effect under N.J.S.A. 17:28-1.1(a). Contrary to the trial court’s view, the Zurich policy did not provide greater UM coverage to any named insured than it provided to Travieso. (pp. 12-13)

2. The Court reviews the language of N.J.S.A. 17:28-1.1(f) and its holding today in Chiaccheri that N.J.S.A. 17:28-1.1(f) was intended to bar step-down provisions that purport to provide employees with less UIM coverage than the coverage afforded to the named insured -- not to require such policies to provide first-party UIM coverage subject to limits equal to the policies’ third-party general liability limits. Id. at ___ (slip op. at 20-25). Chiaccheri found no indication in the plain language or legislative history of N.J.S.A. 17:28-1.1(f) that the statute’s intended purpose was to mandate that UIM coverage equal the general liability limits of a given policy. The Legislature could easily have prescribed such a requirement but did not. (pp. 13-17)

3. N.J.S.A. 17:28-1.1(f) treats UM coverage and UIM coverage in precisely the same manner. Accordingly, the maximum UM coverage “available under the policy” that must be provided to Travieso is coverage up to the UM coverage limit his employer selected under its policy for the named insured, not up to the general third-party liability limit. Here, the applicable UM coverage limit is $15,000. The UM coverage available to Travieso under the Zurich policy met all applicable requirements of N.J.S.A. 17:28-1.1(a) and (b) and provided the same level of UM coverage to Travieso as it provided to the named insureds. Accordingly, the UM provisions of the Zurich policy do not violate either N.J.S.A. 17:28-1.1(f) or New Jersey’s public policy. The Court reverses the trial court’s determination and provides instructions for the proceedings on remand. (pp. 18-19)

REVERSED and REMANDED for further proceedings.

CHIEF JUSTICE RABNER and JUSTICES PIERRE-LOUIS, WAINER APTER, FASCIALE, NORIEGA, and HOFFMAN join in JUSTICE PATTERSON’s opinion.

SUPREME COURT OF NEW JERSEY A-10 September Term 2025

091127

Nicky Travieso and Evette Travieso,

Plaintiffs-Respondents,

v.

Ciara Crespo, Nilda Rivera, John Doe(s), Jane Doe(s), ABC Corporation(s),

and Foulke Management,

Defendants,

and

Zurich American Insurance Company,

Defendant-Appellant.

On appeal from the Superior Court, Appellate Division.

Argued Decided March 31, 2026 August 6, 2026

Louis A. Bové argued the cause for appellant (Bodell Bové, attorneys; Louis A. Bové and Robert D. Fischer, on the briefs).

Matthew G. Bonanno argued the cause for respondents (Rebenack, Aronow & Mascolo, attorneys; Matthew G.

Bonanno, of counsel and on the briefs).

Ryan M. Savercool argued the cause for amicus curiae New Jersey Defense Association (McCarter & English, attorneys; Christopher A. Rojao, of counsel, and Ryan M.

Savercool and Sofia S. Camara, on the brief).

Dominic R. DePamphilis argued the cause for amicus curiae New Jersey Association for Justice (D’Arcy Johnson Day, attorneys; Dominic R. DePamphilis and Richard J. Albuquerque, on the brief).

JUSTICE PATTERSON delivered the opinion of the Court.

In this appeal arising from an insurance coverage dispute between the employee of a named insured and his employer’s insurer, we construe N.J.S.A. 17:28-1.1(f). That provision addresses the limits of uninsured motorist (UM) and underinsured motorist (UIM) coverage available to the named insured’s employee under an automobile liability insurance policy issued to a corporate or business entity. N.J.S.A. 17:28-1.1(f) prohibits an automobile liability policy within the statute’s description from providing “less uninsured or underinsured motorist coverage [to] an individual employed by the corporate or business entity than the coverage provided to the named insured under the policy.” The statute deems “[a] policy that names a corporate or business entity as a named insured” to “provide the maximum [UM] or [UIM] coverage

available under the policy to an individual employed by the corporate or business entity.” N.J.S.A. 17:28-1.1(f).

This appeal concerns the application of N.J.S.A. 17:28-1.1(f) to UM coverage, which is “mandatory first-party coverage insuring the policy holder, and others, against the possibility of injury or property damage caused by the negligent operation of a motor vehicle by an individual without liability insurance coverage.” Badiali v. N.J. Mfrs. Ins. Grp., 220 N.J. 544, 561 (2015) (citing N.J.S.A. 17:28-1.4).

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