Lucero v. Northland Ins. Co.Annotate this Case
A trucking company purchased a liability insurance policy covering its tractors and trailers. The policy stipulated that liability coverage would be limited to "$1,000,000 each ‘accident.’" A tractor-trailer rig insured under the policy was involved in a single accident. The question this case presented for the New Mexico Supreme Court's review centered on whether $1,000,000 was the limit per accident for both vehicles (the tractor and the trailer) or whether each vehicle has liability coverage in the amount of $1,000,000. The district court interpreted the policy to limit its coverage to $1,000,000; the Court of Appeals disagreed and reversed. Because this dispute affects not only the parties to this lawsuit but arguably New Mexico’s place among the many jurisdictions that have grappled with similar policy language, the New Mexico Court granted certiorari. The Supreme Court disagreed with the Court of Appeals and reversed. The Supreme Court found that the Declarations page of the policy at issue provided that the dollar limit was $1,000,000 each accident. Section II(C) of the policy then said the same thing in terms of a "per accident" outside limit on what the insurer would pay: "Regardless of the number of covered ‘autos’ . . . or vehicles involved in the ‘accident’," the most Northland will pay "for the total of all damages . . .resulting from any one ‘accident’ is the Limit of Insurance for Liability Coverage shown in the Declarations [$1,000,000 each accident]." Therefore, the argument advanced by plaintiffs, the Luceros, that the policy provided $1,000,000 in coverage for "'each covered auto in each accident' simply does not find support in the language of the policy. The policy limits Northland’s exposure to $1,000,000 per accident regardless of the number of covered autos involved in any one accident."