821 N.W.2d 621
Minn. Ct. App.2012Background
- Appellants seek uninsured motorist benefits under State Farm for a collision with a farm tractor driven by Schenk in Minnesota.
- Schenk’s tractor had no automobile or general liability insurance; appellants’ pickup was insured with UM coverage.
- District court granted summary judgment, holding a farm tractor is not a motor vehicle under the No-Fault Act or the policy, and not within the reasonable-expectations doctrine.
- Appellants argued (i) tractor could be a motor vehicle under policy or No-Fault Act, or (ii) the doctrine of reasonable expectations could apply.
- The court analyzed three-part definitions of ‘motor vehicle’ and concluded the tractor fails registration and highway-design criteria, so not a motor vehicle.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a farm tractor is a motor vehicle under law and policy | Kastnings claim tractor is a motor vehicle under policy or No-Fault Act | State Farm argues tractor is not a motor vehicle under both definitions | Yes, not a motor vehicle under both definitions |
| Whether the reasonable-expectations doctrine applies | Reasonable-expectations could salvage coverage | Policy language unambiguous; doctrine not applicable | Inapplicable |
Key Cases Cited
- Johnson v. Cummiskey, 765 N.W.2d 652 (Minn.App.2009) (motor-vehicle coverage and exemptions for farm tractors)
- Stepec v. Farmers Ins., 222 N.W.2d 796 (Minn. 1974) (designated for highway use and ambiguity standard)
- Gotta, Great Am. Ins. Co. v., 493 N.W.2d 602 (Minn.App.1992) (farm tractors not motor vehicles under Safety Responsibility Act)
- Carlson v. Allstate Ins. Co., 749 N.W.2d 41 (Minn.2008) (reasonable-expectations limits and ambiguity)
- SECURA Supreme Ins. Co. v. M.S.M., 755 N.W.2d 320 (Minn.App.2008) (reasonable-expectations doctrine applied narrowly)
- Atwater Creamery Co. v. W. Nat. Mut. Ins. Co., 366 N.W.2d 271 (Minn.1985) (extreme situations where doctrine applies)