Campbell v. STATE FARM MUT. AUTO. INS. CO., 12 A.3d 1137

Campbell, a cleaner for Nashed insured by State Farm, was injury victim when a garage door closed on her while she walked under it.
Campbell sought No-Fault benefits as a pedestrian and requested PIP coverage under Delaware Code 21 §2118(a)(1).
Superior Court granted State Farm summary judgment, holding the garage-door incident was not an active accessory of the insured vehicle and thus not a PIP-triggering automobile accident.
Court applied the Klug three-prong test to determine if an injury arises from ownership, maintenance, or use of a vehicle.
Court concluded the vehicle was not an active accessory, the injury was caused by a garage door, and Campbell was not entitled to PIP under statute or policy.
Appellate court affirmed the judgment, upholding denial of PIP coverage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the injury arose from ownership, maintenance, or use of the vehicle	Campbell argues the vehicle's door operation contributed to the injury.	State Farm contends the garage door incident was not caused by the vehicle's ownership, maintenance, or use.	Not an active accessory; no PIP under Klug test.
Whether the garage-door incident qualifies as an automobile accident under 2118	Campbell asserts pedestrian status with injury linked to vehicle activity.	State Farm asserts injury arose from the door, not the vehicle.	No; injury caused by door, not vehicle use.
Whether Campbell qualifies as a pedestrian insured under 2118(a)(2)e	Campbell maintains she was a pedestrian injured by an accident with a motor vehicle.	No vehicle accident occurred; door caused injury.	Inapplicable; injury not from vehicle-related accident.

Nationwide Gen. Ins. Co. v. Royal, 700 A.2d 130 (Del. 1997) (adopts Klug three-part test for whether injury arises from vehicle ownership/use)
Continental Western Ins. Co. v. Klug, 415 N.W.2d 876 (Minn. 1987) (three-part test for whether injury arises from ownership, maintenance or use of a vehicle)