Is A Snowmobile A Motor Vehicle? Yes, Says Court, Upholding Denial Of Coverage

Is a snowmobile a motor vehicle?

That was the question before the U.S. District Court for the Western District of New York, in the recently-issued opinion in Stanton v. Lincoln Life & Annuity Co. of New York, No. 09-CV-6430-CJS (W.D.N.Y. Sept. 2, 2010). Judge Charles Siragusa summarized the case as being an action to recover accidental death insurance benefits, brought pursuant to ERISA, where the decedent was intoxicated and operating a snowmobile when he drove the snowmobile into a tree and was killed. Defendants Lincoln Life & Annuity Company of New York and Jefferson Pilot Life America Insurance Company denied coverage on the grounds that the death was not accidental, since it was a foreseeable result of driving a snowmobile in a wooded area at night at a high speed while intoxicated. The Defendants also denied coverage on the grounds that the policy excluded coverage for losses caused by “driving a motor vehicle while intoxicated.” The plaintiff, a beneficiary of the policy, contended that the denial of coverage was arbitrary.

The policy did not define “motor vehicle.” The plaintiff stated that a snowmobile is not a motor vehicle under New York law. This, the court said, was at least a “partially incorrect” statement. Some New York statutes, the court continued, exclude snowmobile from their definitions. “However, some New York statutes include snowmobiles within the definition of a motor vehicle,” the court noted, citing as an example the definition in New York Insurance Law § 3442(13), which states that “‘Motor vehicle’ means a motor vehicle as defined in section 311 of the vehicle and traffic law . . . and includes a snowmobile . . . .” New York law, then, has “no clear universal standard” of whether the definition of “motor vehicle” excludes or includes a snowmobile. The plaintiff, however, had to show that the denial of coverage was arbitrary. Because there was no standard accepted in all circumstances, the defendants’ decision – to follow a definition that includes “snowmobiles” within the definition of “motor vehicles” – was not arbitrary.

The court granted the defendants’ motion for summary judgment, denied the plaintiff’s cross-motion, and dismissed the action.