Clyde Boyett v. Redland Insurance Co.
2014 U.S. App. LEXIS 1658
| 5th Cir. | 2014Background
- Diversity case; Boyetts seek UM damages under Louisiana statute for North Carolina accident.
- Boeuf River Ventures’ Louisiana auto policy provided liability coverage but no UM; no valid Louisiana UM waiver attached.
- Accident occurred while a forklift was used by Carolina Lumber employee unloading lumber from Boyett’s tractor-trailer.
- District court granted Redland summary judgment on liability coverage and denied on UM coverage, later concluding forklift was not a motor vehicle for UM purposes.
- Court and parties debated whether Louisiana UM statute (La. Rev. Stat. § 22:1295) applies to out-of-state accidents and whether forklift qualifies as a motor vehicle.
- Appeal challenges district court’s ruling restricting statutory UM coverage; majority holds forklift is a ‘motor vehicle’ for UM purposes and UM may apply despite accident occurring outside Louisiana.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Louisiana’s UM statute applies to out-of-state accidents. | Boyetts: statute may apply; Louisiana UM law extends geographically. | Redland: statute does not apply to out-of-state accidents. | Yes, statute may apply to out-of-state accidents. |
| Whether a forklift is a “motor vehicle” under La. Rev.Stat. § 22:1295. | Forklift is a motor vehicle for UM purposes. | Forklift is not designed for highway use and not a Louisiana motor vehicle. | Forklift is a “motor vehicle” for UM purposes. |
| Whether uninsured/underinsured motor vehicle identification should be limited by policy language. | Statutory UM coverage cannot be defeated by liability-policy exclusions. | Policy exclusions may constrain UM coverage. | Statutory UM coverage applies notwithstanding policy exclusions. |
| How to interpret the term “motor vehicle” in light of Louisiana civil-law approach (Erie guess). | Court applies Louisiana civilian interpretation; forklift fits broad “motor vehicle” reading. |
Key Cases Cited
- Snider v. Murray, 461 So.2d 1051 (La.1985) (scope of UM statute prior to amendment; policy delivered in another state)
- Champagne v. Ward, 893 So.2d 773 (La.2005) (UM coverage with public policy; multistate considerations)
- Transcon. Gas Pipe Line Corp. v. Transp. Ins. Co., 953 F.2d 985 (5th Cir.1992) (civil-law approach; jurisprudence constante)
- Eagle Pipe & Supply, Inc. v. Amerada Hess Corp., 79 So.3d 246 (La.2011) (civilian doctrine; jurisprudence constante authority)
- Hoefly v. Gov't Emps. Ins. Co., 418 So.2d 575 (La.1982) (UM statute interpretation in Louisiana)
- A.I.U. Ins. Co. v. Roberts, 404 So.2d 948 (La.1981) (interpretation of UM coverage; statutory purpose)