Lancer Insurance Co. v. Lake Shore Motor Coach Lines, Inc., 2017 UT 8

On Oct. 10, 2009 a Lake Shore Motor Coach Lines bus driven by Debra Jarvis left the roadway and rolled after Jarvis suffered a sudden, unforeseeable loss of consciousness; several passengers were injured.
Injured passengers (Crane, Hutchison, Thayne, Seppi) sued in Utah state court for damages; motions for partial summary judgment seeking to treat the incident as strict liability under Utah Code § 31A-22-303(1) were denied by the state district court, which preserved the common-law “sudden incapacity” defense.
Lancer Insurance (insurer for Lake Shore) separately filed a federal declaratory-judgment action seeking confirmation that § 31A-22-303(1) preserves the sudden-incapacity defense (i.e., no strict liability absent proof of fault).
The federal district court certified two questions to the Utah Supreme Court: (1) whether § 31A-22-303(1) imposes strict liability for unforeseeable incapacity while driving; and (2) whether any liability is limited to the policy limits or to statutory minimum limits.
The Utah Supreme Court accepted certification and interpreted § 31A-22-303(1) to (a) override the common-law sudden-incapacity defense and impose strict liability when the statutorily required coverage exists, and (b) cap liability at the applicable insurance policy’s coverage limits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 31A‑22‑303(1) imposes strict liability for damages caused by a driver’s unforeseeable paralysis, seizure, or loss of consciousness	Statute requires coverage for such harms and thus overrides the sudden‑incapacity defense—no proof of negligence needed	Statute merely mandates insurers to provide coverage; it does not impose tort liability on drivers	Court: § 31A‑22‑303(1) effectively repudiates the sudden‑incapacity defense and imposes strict liability where the required coverage is present
Whether driver’s liability is limited to the policy’s coverage or to statutory minimum limits	Injured parties: liability should be satisfied up to the available insurance coverage (as statute refers to "insurance coverage")	Lancer: argued for a narrower reading or reliance on statutory minimums (implicitly)	Court: liability is limited to the actual insurance coverage available under the applicable policy, not merely statutory minimums

Porter v. Price, 355 P.2d 66 (Utah 1960) (adopted the common‑law sudden incapacity defense)
Hansen v. Heath, 852 P.2d 977 (Utah 1993) (discussing scope of sudden incapacity rule)
Randle v. Allen, 862 P.2d 1329 (Utah 1993) (overruling parts of earlier precedent on other grounds; cited for statutory interpretation context)