401 P.3d 891
Wyo.2017Background
- On May 31, 2014, Hannah Terry (uninsured) struck two bicyclists, Larry and Sara Hurst, while driving a minivan; Larry died and Sara suffered severe injuries. The two impacts were about 30 feet and ~0.5–1 second apart.
- The Hursts are insured under a MetLife policy providing UIM limits of "$300,000 each person / $300,000 each accident." The policy does not define "one accident."
- MetLife deposited $300,000 into court, asserting both injuries arose from a single accident (so the $300,000 per-accident cap applies). The Hursts argued there were two accidents, triggering $600,000.
- Parties filed cross-motions for summary judgment on whether the collisions constituted one or two "accidents" for UIM limit purposes; the district court granted judgment for MetLife, finding one accident under the cause (causation) theory.
- The Wyoming Supreme Court adopted the cause theory as the appropriate rule for determining "one accident," but reversed summary judgment because the stipulated facts did not resolve whether Terry maintained or regained control of her vehicle between impacts — a controlling factual element under the cause test — requiring remand for further factfinding.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the two strikes constitute one or two "accidents" for UIM limits | Hursts: two separate accidents → $600,000 total (effect or multiple-occurrence view) | MetLife: a single proximate, uninterrupted cause → one accident → $300,000 limit | Court: adopt cause theory to define "accident," but remand because factual record is inconclusive on control element |
| Proper legal test to define "one accident" | Hursts: prefer effect theory (limits apply per injured person) | MetLife: majority cause theory is correct | Court: adopts the cause (causation) theory as controlling in Wyoming |
| Application of cause theory to stipulated facts | Hursts: spatial/temporal closeness still supports two accidents or at least creates factual dispute | MetLife: 30 feet and ~1 second show a single continuous cause | Court: neither party proved whether driver lost or maintained control; facts inconclusive — summary judgment improper |
| Whether policy language is ambiguous | Hursts: ambiguity favors insured (argue broader reading) | MetLife: language unambiguous; limits apply per accident | Court: policy language interpreted under contract principles; not ambiguous for a reasonable insured, but legal definition requires adopting a test (cause theory) |
Key Cases Cited
- State Auto Prop. & Cas. Co. v. Matty, 690 S.E.2d 614 (Ga. 2010) (endorses cause theory and explains why effect theory is improper for liability limits)
- Am. Family Mut. Ins. Co. v. Wilkins, 179 P.3d 1104 (Kan. 2008) (discusses multi-factor cause analysis and role of control in separating occurrences)
- Just v. Farmers Auto. Ins. Ass’n, 877 N.W.2d 467 (Iowa 2016) (analyzes cause, effect, and event tests and treatment of intervening causes)
- Saint Paul-Mercury Indem. Co. v. Rutland, 225 F.2d 689 (5th Cir. 1955) (criticizes effect theory as creating potentially limitless insurer exposure and supports cause-based limits)