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Eleventh Circuit Declines to Limit Scope of Uninsured Motorist Coverage to that Required by Florida

State Farm Mut. Auto. Ins. Co. v. Spangler

By James K.A. Miller

The United States Court of Appeals for the Eleventh Circuit addressed whether the plain meaning or a related statutory definition of a term dictated the scope of coverage for an insurance policy when an operative term in the policy was undefined. In reversing the United States District Court for the Middle District of Florida’s grant of summary judgment in favor of State Farm, the Eleventh Circuit reasoned that the plain meaning of the term “land motor vehicle” in the policy’s “Uninsured Motor Vehicle” (“UM”) section controlled where the term was undefined, thus providing more coverage than required by Florida law.

The court therefore held that Florida’s Financial Responsibility Law (“FRL”), in conjunction with its Uninsured Motorist Statute (“UM statute”), only establishes the minimum level of coverage for accidents involving an uninsured driver, and broader policies can be defined by the parties or interpreted by courts in the absence of a defined term.

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