Staker & Parson Companies, Inc. v. Scottsdale Insurance Company1 min read

Arizona Supreme Court: Staker & Parson Companies v. Scottsdale Insurance Company  Case No. CV-21-0256-CQ    Filed July 10, 2024

ISSUES:

1. Whether an additionally named insured is “using” a covered vehicle when transporting cargo
2. Whether maintenance of private roads owned by the additionally named insured constitutes “use”
3. Whether managerial functions like safety training constitute “use” of a covered vehicle
4. Causal relationship between vehicle use and injury in insurance context

DECISION:

1. Transporting an additionally named insured’s cargo constitutes “use” without requiring active control by the additionally named insured
2. Maintenance of private roads owned by the additionally named insured does not independently constitute “use”
3. Managerial functions like safety training do not constitute “use” of a covered vehicle
4. Causation requires a connection between the accident and negligent ownership, maintenance, or use of the covered vehicle, but not necessarily the proximate cause

Synopsis:
The Arizona Supreme Court addressed four certified questions from the U.S. District Court for the District of Utah regarding the interpretation of “use” in commercial automobile liability insurance policies. The court expanded on the definition of “use” to include loading, unloading, and transporting cargo, but limited its scope to exclude premises liability and managerial functions. The decision also clarified the causation standard in insurance contexts, requiring a connection between the accident and negligent use of the vehicle.

Outcome of the Case:
The court answered the first certified question affirmatively, the second and third questions negatively, and provided guidance on causation for the fourth question.