64 F.4th 1173
11th Cir.2023Background
- Richard and Anna Spangler held a State Farm auto policy with UM coverage; the policy’s UM section defined “uninsured motor vehicle” in relevant part as a “land motor vehicle,” but did not itself define “land motor vehicle.”
- The Policy’s general Definitions section did define “motor vehicle” as a self‑propelled vehicle with four or more wheels designed for and required to be licensed for use on Florida highways; those general definitions applied only where terms were in bold/italics and “land motor vehicle” was not.
- Anna Spangler was struck on a Florida public road by a Razor Pocket Mod electric scooter (two wheels, 250W motor, 15 mph top speed, battery powered, unregistered, no VIN); the scooter’s uninsured driver died and Anna suffered serious injuries.
- State Farm denied the UM claim, sued for a declaratory judgment that the Policy provided no coverage, and the district court granted summary judgment to State Farm, relying on Florida’s Financial Responsibility Law (FRL) definition of “motor vehicle.”
- On appeal the Eleventh Circuit considered whether the undefined Policy term “land motor vehicle” should be given its plain and ordinary meaning (as the Spanglers urged) or limited by the FRL statutory definition of “motor vehicle” (as State Farm urged).
- The Eleventh Circuit reversed the district court, holding that the Policy’s plain meaning of “land motor vehicle” includes the Razor scooter and that an insurer may lawfully provide UM coverage broader than the FRL requires.
Issues
| Issue | Plaintiff's Argument (Spangler) | Defendant's Argument (State Farm) | Held |
|---|---|---|---|
| Whether the Razor Pocket Mod is an “uninsured motor vehicle” under the Policy (Policy defines UM vehicle as a “land motor vehicle”) | “Land motor vehicle” should be given its plain and ordinary meaning, which covers a battery‑powered two‑wheeled scooter designed to transport a rider on the solid surface of the earth. | The scooter is not a covered motor vehicle because it is not a “motor vehicle” as defined elsewhere in the Policy or under Florida’s FRL. | Held for Spanglers: the plain meaning of “land motor vehicle” includes the Razor Pocket Mod. |
| Whether the Policy’s general definition of “motor vehicle” (four+ wheels, licensed for highway use) applies to the UM section | The general definition does not apply because the Policy limits the scope of those definitions to bold/italic terms and “land motor vehicle” was not defined there. | The Policy should be read consistently with its general Definitions or Florida statutory definitions to avoid providing broader coverage than required. | Held for Spanglers: the general Definition did not apply to the UM term at issue; court deferred to the plain meaning of the undefined UM term. |
| Whether Florida’s FRL statutory definition of “motor vehicle” controls interpretation of the Policy term “land motor vehicle” | Even if FRL supplies a minimum scope, the insurer may provide broader UM coverage by contract; the Policy’s unambiguous language governs. | FRL’s definition should govern UM terms to effectuate the statutory scheme and ensure parity with FRL requirements. | Held for Spanglers: FRL does not displace the plain meaning here; insurer may lawfully provide broader coverage than the FRL minimum. |
Key Cases Cited
- Grant v. State Farm Fire & Cas. Co., 638 So. 2d 936 (Fla. 1994) (discussed use of FRL definition of “motor vehicle” where UM term was undefined and FRL definition matched the term at issue)
- Carguillo v. State Farm Mut. Auto. Ins. Co., 529 So. 2d 276 (Fla. 1988) (held UM exclusions must be consistent with FRL and UM statute purposes; FRL sets minimums)
- State Farm Fire & Cas. Co. v. CTC Dev. Corp., 720 So. 2d 1072 (Fla. 1998) (undefined policy terms are given common everyday usage)
- Gov’t Emps. Ins. Co. v. Macedo, 228 So. 3d 1111 (Fla. 2017) (when a policy term is undefined, it should receive its plain and ordinary meaning)
- Mullis v. State Farm Mut. Auto. Ins. Co., 252 So. 2d 229 (Fla. 1971) (describing the UM statute’s purpose to place an injured party in the same position as if the tortfeasor had complied with FRL)