Keene Auto Body, Inc. v. State Farm Mutual Automobile Insurance Company
Annotate this CasePlaintiff Keene Auto Body, Inc. appealed a circuit court order that dismissed its complaint against defendant State Farm Mutual Automobile Insurance Company. Keene Auto Body, acting as an assignee of Caleb Meagher, who insured his vehicle through State Farm, sued State Farm for breach of contract for failing to cover the full cost of repairs to the insured’s vehicle. State Farm moved to dismiss the suit on grounds that, because of an anti-assignment clause in the insured’s policy, the insured’s assignment of his breach of contract claim to Keene Auto Body was not valid, and that, even if it was, Keene Auto Body did not sufficiently state a claim for breach of contract. The trial court granted the motion. The New Hampshire Supreme Court found the anti-assignment clause at issue here was ambiguous, and construed it against the insurer. Therefore, the clause did not prohibit the insured from assigning his post-loss claim to Keene Auto Body. Given this holding, the Supreme Court determined Keene Auto Body's factual allegations were sufficient to survive State Farm's motion to dismiss. Judgment was reversed and the matter remanded for further proceedings.
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