State Farm Mut. Auto. Ins. Co. v. Estate of Carey
Annotate this CaseThis appeal arose from a motor vehicle collision involving Roger Linton and James Carey that resulted in Carey's death. At the time of the collision, Linton was driving a truck owned by Jonathan Jennings, for whom Linton worked as an independent contractor. Jennings's insurer, State Farm, filed a declaratory judgment action against Carey's Estate and Linton to determine whether it was responsible for liability coverage and obligated to defend and indemnify Linton for claims arising from the collision. The superior court entered a judgment in favor of State Farm, concluding that Linton was not an insured covered by Jennings's policy because his use of the truck was not within the scope of Jennings's consent. At issue on appeal was whether the superior court erred in its application of the minor deviation rule in determining that Linton's use of the truck exceeded the scope of Jennings's consent. The Supreme Court vacated the judgment, clarified the applicable burdens associated with the minor deviation rule, and remanded for the superior court to apply the minor deviation rule as clarified.
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