Barbara Bennett v. State Farm Mutual Automobile Ins.
731 F.3d 584, 2013 WL 5312398, 2013 U.S. App. LEXIS 19494 (2013)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
When an insurance policy provides an explicit definition for a term, that definition controls the interpretation of the contract, even if it deviates from the term's ordinary meaning.
Facts:
- On November 9, 2010, Barbara Bennett was walking her dog along a road.
- Robert Pastel, driving a Ford Fusion insured by State Farm, negligently struck Bennett with the vehicle.
- The impact first struck Bennett on her left knee.
- The force of the collision threw Bennett onto the hood of the Ford Fusion.
- Bennett sustained additional bodily injuries while she was on the vehicle's hood.
Procedural Posture:
- Barbara Bennett filed a declaratory judgment action against State Farm Mutual Automobile Insurance Company in the U.S. District Court for the Northern District of Ohio (trial court).
- The district court granted summary judgment in favor of State Farm, holding that Bennett was not an 'occupant' under the policy.
- Bennett, as the appellant, appealed the district court's decision to the U.S. Court of Appeals for the Sixth Circuit.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Is a pedestrian who is struck by a vehicle and thrown onto its hood considered an 'occupant' for insurance coverage purposes when the policy defines 'occupying' as being 'in, on, entering or alighting from' the vehicle?
Opinions:
Majority - Kethledge, J.
Yes. A pedestrian thrown onto the hood of a car is an 'occupant' when the insurance policy explicitly defines 'occupying' to include being 'on' the vehicle. The court must interpret a contract according to its explicit terms, not by its ordinary English usage, especially when a term is specifically defined. State Farm's policy defined 'occupying' as 'in, on, entering or alighting from.' The parties stipulated that Bennett was 'on' the Fusion's hood where she sustained further injuries. Therefore, under the policy's plain language, she was an 'occupant' and is entitled to coverage. The court rejected State Farm's reliance on precedents where plaintiffs were merely adjacent to or under a vehicle, and it also dismissed the 'intrinsic-relationship' test because that test only applies in ambiguous, 'gray area' situations, whereas the policy's definition here was crystal clear.
Analysis:
This decision strongly reinforces the fundamental principle of contract law that unambiguous, defined terms in a written agreement will be strictly enforced as written. It serves as a pointed reminder to insurance companies that the specific language they draft into their policies is controlling, and they cannot later argue for a term's common meaning or an external legal test when their own policy provides a clear definition. The case demonstrates that courts will prioritize the text of the contract over arguments about what a 'typical' or 'reasonable' outcome should be. This precedent limits the application of judicial 'gray area' tests to situations where policy language is genuinely ambiguous.
