Marlin Lee Just, Noelle Marie Marchant Hughes, and Travis Clinton Hughes v. Farmers Automobile Insurance Association D/B/A Pekin Insurance
2016 Iowa Sup. LEXIS 40
| Iowa | 2016Background
- On April 29, 2011, John Crivaro drove an SUV the wrong way on a divided highway and collided with Marlin Just’s southbound semi; Crivaro was ejected and killed and the SUV was wrecked.
- Seconds later Travis Hughes, riding a motorcycle behind the semi, collided with Crivaro’s disabled SUV which remained in the lanes; Hughes suffered severe injuries.
- Crivaro’s auto policy with Farmers provided $500,000 bodily-injury liability "for each person, each accident" and stated that this is the most the insurer will pay "regardless of the number of... Vehicles involved in the auto accident." "Accident" is undefined.
- Just and Hughes sought a declaratory judgment that the two impacts constituted two separate "accidents" (entitling them to two policy limits); Farmers sought a declaration there was one accident.
- The district court granted Farmers’ summary-judgment motion; the Iowa Supreme Court affirmed, applying the majority "cause theory": both impacts flowed from a single proximate cause in close temporal and spatial proximity, so only one accident occurred.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the chain‑reaction collisions constitute one or multiple "accidents" under an undefined "accident" clause | Just/Hughes: Each collision is a separate accident; policy limit applies per impact | Farmers: Events form one accident; policy limit applies once because language covers multi‑vehicle accidents | One accident: court applies the cause theory and enforces single per‑accident limit |
Key Cases Cited
- Auto-Owners Ins. Co. v. Munroe, 614 F.3d 322 (7th Cir. 2010) (chain‑reaction multi‑vehicle collision held a single occurrence where collisions flowed from one uninterrupted cause)
- State Auto Prop. & Cas. Co. v. Matty, 690 S.E.2d 614 (Ga. 2010) (adopting cause theory for policy with "regardless of the number of...vehicles" language; multiple impacts seconds apart are one accident)
- Saint Paul–Mercury Indem. Co. v. Rutland, 225 F.2d 689 (5th Cir. 1955) (cause‑theory discussion rejecting effect‑based approach that would treat each injured party as a separate accident)
- Truck Ins. Exch. v. Rohde, 303 P.2d 659 (Wash. 1956) (applying proximate cause to treat multiple impacts as a single accident under per‑accident limits)
- Goodwin v. Zurich Am. Ins. Co., 920 So.2d 427 (Miss. 2006) (discussing perspectives—insured vs. injured—and forecasting Iowa would adopt insured‑focused/cause analysis)
- Kan. Fire & Cas. Co. v. Koelling, 729 S.W.2d 251 (Mo. Ct. App. 1987) (finding one accident where collisions occurred almost simultaneously and policy limited liability regardless of number of vehicles involved)