Berg v. Metropolitan Property and Casualty Insurance Company

Background

Thomas Berg was injured in late August 2020 when the motorcycle he was riding collided with a car driven by an uninsured motorist. For purposes of the summary-judgment motion, the parties accepted that the uninsured driver was negligent and responsible for the collision. Berg owned the motorcycle and was injured in the accident.

Berg insured the motorcycle through Progressive Insurance Company. Thomas and Zelda Berg also maintained insurance on two cars through Metropolitan Property and Casualty Company. The Progressive policy did not provide uninsured-motorist coverage. The Bergs’ lawsuit argued that uninsured-motorist coverage under the Metropolitan policy applied to the accident.

Policy Language and Arguments

The Metropolitan policy listed a 2014 Jeep and a 2015 Jeep as covered autos. Its uninsured-motorist provision broadly covered an insured who suffered bodily injury in an accident arising from the use of an uninsured motor vehicle. But the provision excluded a person “occupying or struck by a motor vehicle owned by you or a relative, other than a covered auto.”

Metropolitan argued that this exclusion applied because Berg’s motorcycle was owned by him and was not one of the policy’s covered autos. Berg argued that the policy’s definition of “Motor Vehicle” did not include motorcycles. He relied on the policy’s separate definitions of “Motorcycle” and “Motor Vehicle,” contending that the policy treated them as different categories.

Court’s Analysis

Applying Minnesota law, the court explained that insurance-policy exclusions must be interpreted narrowly and strictly against the insurer. Policy terms ordinarily receive their usual meaning unless the policy gives them a different meaning.

The policy defined “Motor Vehicle” as “a land motor vehicle designed for use mainly on public roads,” while separately defining “Motorcycle” immediately before that definition. The court found that the policy’s apparent distinction between the two terms created an ambiguity about whether a motorcycle was a “motor vehicle” for purposes of the uninsured-motorist exclusion.

Minnesota law requires ambiguities in insurance policies to be resolved in favor of the insured. Because the exclusion applied only to a person occupying a “motor vehicle” owned by the insured or a relative, and because the policy was ambiguous about whether that term included a motorcycle, the court construed the policy to provide coverage here.

Disposition

The court denied Metropolitan’s Motion for Summary Judgment. The opinion did not enter a final judgment on the underlying insurance dispute; it ruled that the policy’s exclusion did not establish as a matter of law that Berg’s injuries were outside the coverage grant.