97 F.4th 1223
10th Cir.2024Background
- Bryar Johnson was injured in a Tulsa, Oklahoma, motorcycle accident involving two vehicles; he collected the liability limits from both other drivers’ insurance policies, but his damages exceeded these amounts.
- Bryar sought additional uninsured motorist (UM) benefits from his parents’ MetLife automobile policy as a resident-relative insured.
- MetLife denied the claim based on a policy exclusion: no UM coverage for resident relatives injured while operating their own motor vehicle, unless that vehicle is covered by a "motor vehicle insurance policy."
- Bryar had only liability (not UM) insurance on his motorcycle from GEICO, having declined offered UM coverage.
- The district court held for MetLife, ruling the exclusion applied since Bryar did not carry UM coverage on his motorcycle; the court also denied Bryar’s motion to amend his complaint to add a bad-faith claim as time-barred.
- On appeal, the Tenth Circuit was asked to interpret whether the exclusion properly denied Bryar UM coverage under Oklahoma law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MetLife’s UM exclusion applies when the claimant carried only liability insurance on his vehicle | Liability insurance satisfies "motor vehicle insurance policy" requirement; thus, exclusion does not apply | Policyholder must carry UM coverage on their own vehicle for resident-relative UM claims; exclusion bars recovery | Exclusion does not apply; liability policy suffices |
| Significance of Bryar’s opportunity to purchase UM coverage | Opportunity to purchase UM coverage is irrelevant; policy language controls | Bryar’s rejection of UM coverage should preclude his recovery under parents’ policy | Opportunity to purchase is not determinative; policy language is dispositive |
| Effect of prior case law regarding resident relatives and UM exclusions | Coates allows recovery when accident vehicle insured by liability policy, even without UM | Prior cases require resident-relative to carry UM coverage on own vehicle | Coates controls; policy could have required UM coverage, but did not |
| Denial of motion to amend for bad-faith claim | Denial tied to erroneous coverage decision; should be reversed | Claim is time-barred under statute of limitations | Affirmed; claim remains time-barred |
Key Cases Cited
- Coates v. Progressive Direct Ins. Co., 512 P.3d 345 (Okla. 2022) (holding a "motor vehicle insurance policy" includes liability or UM coverage, so a resident-relative exclusion does not apply if a vehicle carries liability insurance, even if UM coverage is declined)
- Morris v. America First Ins. Co., 240 P.3d 661 (Okla. 2010) (addressing policy language requiring separate UM coverage for resident-relative to claim benefits under another policy)
- Conner v. American Commerce Insurance, 216 P.3d 850 (Okla. Civ. App. 2009) (upholding UM exclusion where resident-relative had declined UM coverage on owned vehicle)