Locke v. Estate of DavisAnnotate this Case
Marian Davis lost control of her vehicle and struck a vehicle driven by Amy Locke. At the time of the accident, Davis was insured by Safeco Insurance Company under a policy with a $100,000 per person coverage. Davis died from her injuries. Locke, who also sustained injuries, filed a claim for damages against Davis’s estate. Prior to trial, Safeco paid Locke $16,306 for her past medical expenses. After a trial, the jury awarded Locke $400,000 in compensation for her injuries. The Estate appealed, and Safeco intervened. The Supreme Court affirmed in part and vacated and remanded in part, holding that the district court (1) abused its discretion in denying the Estate’s motion to alter or amend the judgment because Locke was precluded from recovering against the Estate more than the $100,000 insurance limitation; and (2) did not abuse its discretion when it made findings and conclusions that effectively bound Safeco to a judgment in a case in which Safeco was not a named party, was not represented by counsel, and did not appear.