James River Insurance Co. v. Doswell Truck Stop, LLC
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In this insurance coverage dispute, the Supreme Court reversed the judgment of the circuit court ruling in favor of Doswell Truck Stop, LLC (DTS) on DTS's declaratory judgment action against James River Insurance Company and entered final judgment declaring that an auto exclusion precluded coverage of James Smith's injuries under the policy at issue, holding that the trial court erred in ruling in favor of DTS.
Smith filed a personal injury lawsuit against DTS for injuries he allegedly suffered as a result of a tire explosion that occurred when DTS was repairing a tire on Smith's tractor-trailer. DTS filed an insurance claim with James River, which had issued a commercial general liability policy to DTS. James River denied coverage on the basis that DTS's claim was precluded by the auto exclusion. DTS then filed this action seeking a determination of whether the policy covered Smith's injury. The circuit court ruled in favor of DTS. The Supreme Court reversed, holding (1) the circuit court erred determining that the auto exclusion was ambiguous with respect to the meaning of "maintenance" of an auto; and (2) the circuit court erred in ruling that an independent basis existed for coverage under the policy.
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