Farmers Insurance Exchange v. Rodriguez, 366 S.W.3d 216

Rodriguez was injured while helping Woodling remove a deer stand from Woodling's trailer.
Rodriguez sued Woodling for negligence and Allstate for uninsured/underinsured motorist (UIM) coverage; Rodriguez later added Farmers seeking coverage under its homeowner's policy.
Pre-trial partial summary judgment declared that both Farmers and Allstate policies potentially provided coverage.
The jury found Woodling negligent and Rodriguez damaged; post-trial, the court held Rodriguez's injuries were covered under both Farmers and Allstate policies.
Farmers moved to dismiss for lack of subject-matter jurisdiction, arguing Rodriguez's claim against Farmers was not ripe because Woodling’s liability had not yet been adjudicated.
Allstate challenged coverage under its UIM policy; Farmers challenged the appellate jurisdiction; the court ultimately held Farmers’ claim was not ripe and Allstate’s coverage valid.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rodriguez's claim against Farmers was ripe	Rodriguez contends ripeness exists due to undisputed facts.	Farmers argues lack of final judgment on Woodling's liability prevents ripeness.	Rodriguez's claim against Farmers not ripe; dismiss for lack of jurisdiction.
Whether the Farmers homeowners policy provides coverage for Woodling	Rodriguez seeks indemnity under Farmers, arguing no exclusion applies.	Farmers asserts the exclusion for trailers excludes the claim.	Not reached due to lack of ripeness; reversed as to lack of jurisdiction and dismissed.
Whether Rodriguez's injury is covered under Allstate's UIM policy	Rodriguez contends the injury arose out of use of a trailer and is within UIM coverage.	Allstate argues loading/unloading or use does not bring the injury within coverage.	UIM coverage applies; injury arose out of the use of the trailer; summary and declaratory judgments in Rodriguez’s favor affirmed.
Whether Rodriguez's injury arose out of the ownership, maintenance or use of the vehicle under the Allstate policy	Rodriguez asserts broad interpretation of 'use' includes unloading a trailer.	Allstate contends narrow interpretation; excludes loading/unloading.	Use includes unloading and loading under complete operation doctrine; Rodriguez's injury covered.

Angus Chem. Co. v. IMC Fertilizer, Inc., 939 S.W.2d 138 (Tex. 1997) (no direct insurance implication; cited for general principles)
State Farm Cnty. Mut. Ins. Co. of Tex. v. Ollis, 768 S.W.2d 722 (Tex. 1989) (third-party beneficiary cannot enforce policy until judgment against insured)
Great Am. Ins. Co. v. Murray, 437 S.W.2d 264 (Tex. 1969) (premature adjudication policy; no direct action before judgment)
Firemen's Ins. Co. v. Burch, 442 S.W.2d 331 (Tex. 1968) (insurer indemnity duty not ripe before judgment; limited exception)
Griffin v. Farmers Tex. Cnty. Mut. Ins. Co., 955 S.W.2d 81 (Tex. 1997) (exception to no-coverage before judgment; not applicable here)
D.R. Horton-Tex., Ltd. v. Markel Int'l Ins. Co., 300 S.W.3d 740 (Tex. 2009) (distinguishes Griffin; duty to indemnify not adjudicated before judgment)
Mid-Continent Cas. Co. v. Global Enercom Mgmt., Inc., 323 S.W.3d 151 (Tex. 2010) (framework for determining 'use' in UIM context)
Liberty Mut. Ins. Co. v. Am. Int'l Specialty Lines Ins. Co., 438 F.3d 225 (5th Cir. 2006) (complete operation doctrine; loading/unloading included)
Travelers Ins. Co. v. Emp’r's Cas. Co., 380 S.W.2d 610 (Tex. 1964) (complete operation doctrine context)
Panhandle Steel Prods. Co. v. Fidelity Union Cas. Co., 23 S.W.2d 799 (Tex. Civ. App.-Fort Worth 1929) (loading/unloading framework in use analysis)