Court Says Florida Auto Insurance Policy Doesn’t Cover Off-Road Vehicle – Baldassini v. State Farm

Insurance policies can often be complex documents that are rife with legalese and leave a policy holder wondering just what it is that’s covered by the contract. In Baldassini v. State Farm, the U.S. Court of Appeals for the Eleventh Circuit explains that state law requires that the terms of an insurance contract be interpreted according to their “plain meaning.” In this case, that meant a specific automobile insurance policy didn’t extend coverage to off-road, electric vehicles.

Mr. Fiallo was injured in an accident in Key Biscayne when he was struck by an ST Express, a four-wheel electric vehicle, driven by Ms. Baldassini. The driver was 15 years old at the time of the accident, and her family was caring for the vehicle while its owner was away on a trip. Fiallo later sued Baldassini, her parents and the vehicle’s owner for negligence. State Farm, the insurance company under which the owner held a recreational vehicle policy, eventually paid Fiallo $100,00 for his injuries. Although the Baldassinis also held an automobile insurance policy with State Farm, the company denied their request for coverage, finding that this particular policy didn’t cover recreational vehicles. The family ultimately settled with Fiallo and assigned to him their legal right to pursue coverage under the State Farm policy.

The insurance company then filed suit in federal court in Florida, seeking a declaratory judgment stating that the ST Express accident wasn’t covered under the Baldassinis’ policy. The district court agreed, finding that the policy’s terms were unambiguous and clearly limited coverage to traditional automobiles.

The Eleventh Circuit agreed on appeal. The court explained that Florida law requires that insurance contracts be interpreted according to their “plain meaning.”

“Because unambiguous policy terms are enforced as they are written and because the ST Express does not fit within the plain meaning of the definition of ‘car’ in State Farm’s contract, that contract does not cover Fiallo and the Baldassinis’ claim,” the Court concluded. Specifically, the policy defined the term “car” as “a land motor vehicle with four or more wheels, which is designed for use mainly on public roads.” The Court said the ST Express didn’t fall within this definition because it wasn’t designed for use on public roads. It noted in particular that the vehicle’s user manual stated that it was meant for off-road use. In fact, the Court said the vehicle’s manufacturer even placed a sticker near the dashboard warning users not to take the vehicle on highways.

As a result, the Eleventh Circuit affirmed the declaratory judgment for State Farm.

If you have been injured in a car accident or are involved in a related insurance dispute, it is important to have experienced legal counsel in your corner. Contact the South Florida car accident lawyers at Anidjar & Levine. From offices in Ft. Lauderdale, our experienced car accident and insurance attorneys serve clients throughout the region, including in Hialeah, Coral Springs and Pompano Beach. Call us toll-free at 800-747-3733 or contact us online to schedule a free consultation.

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