STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, APPELLANT,
v.
RICHARD K. CHAPMAN, APPELLEE
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State Farm denied personal injury protection (PIP) coverage to Chapman, who was injured while operating a state-owned Highway Patrol vehicle, based on a policy exclusion for government-owned vehicles. The trial court entered a declaratory judgment finding the exclusion violated Florida's Automobile Reparations Reform Act, and the appellate court affirmed, holding that government vehicles fall within the statutory definition of 'motor vehicles' and cannot be excluded from mandatory PIP coverage.
The court held that government-owned vehicles constitute 'motor vehicles' under Florida's Automobile Reparations Reform Act and therefore cannot be excluded from mandatory PIP coverage. Policy provisions purporting to comply with the act must be enforced as if in full compliance, irrespective of actual terms, and Chapman was entitled to declaratory judgment confirming his PIP coverage.
[1] An insurance policy providing personal injury protection benefits under Florida's Automobile Reparations Reform Act must be enforced as written, even if its terms conflic…
[2] A policy exclusion denying coverage for occupants of government-owned vehicles is impermissible under Florida's Automobile Reparations Reform Act.
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Join FLexlaw to unlock all legal intelligence“Any insurance policy purporting to provide security in accordance with Florida's Automobile Reparations Reform Act is to be enforced as if it were in compliance with the act, irrespective of its actual terms.”
Establishes the core principle that policies must be treated as compliant with the statutory act regardless of conflicting policy language
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Join FLexlaw to unlock all legal intelligenceOn November 10, 1979, Chapman was injured while operating a Florida Highway Patrol vehicle owned by the state. Chapman demanded personal injury protec…
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COBB, Judge.
On November 10, 1979, Chapman was injured while he was operating a Florida Highway Patrol vehicle owned by the state. Chapman made a demand upon State Farm for personal injury protection benefits. State Farm refused to. pay the benefits on the basis that Chapman was excluded from coverage at the time of the accident due to the terms of the policy.
Chapman filed a complaint for declaratory relief, which sought a judgment as to whether he was entitled to the personal injury protection coverage. State Farm filed an amended answer in which it denied coverage because the policy excluded from coverage anyone occupying a vehicle owned by any government. State Farm’s amended answer also denied coverage because any personal injury protection benefits due to Chapman must be reduced by workmen’s compensation benefits paid or payable to him.
State Farm moved for summary judgment. Chapman moved for judgment on the pleadings. The trial court denied State Farm’s motion for summary judgment and granted Chapman’s motion for judgment on the pleadings. The trial court then entered a declaratory judgment in which it found State Farm’s exclusion of a government-owned vehicle to be statutorily impermissible and that State Farm’s argument with regard to workmen’s compensation benefits only had a bearing on the amount of personal injury protection benefits to which Chapman might be entitled, rather than the issue of whether he had personal injury protection coverage. The trial court then rendered a declaratory judgment that the State Farm policy did provide personal injury protection coverage to Chapman.
Florida’s Automobile Reparations Reform Act requires the insurer of the owner of a motor vehicle to pay personal injury protection benefits for the accidental bodily injury sustained in this state by the owner while he is occupying a motor vehicle. § 627.736(4)(d)l, Fla.Stat. (1981). Any insurance policy purporting to provide security in accordance with Florida’s Automobile Reparations Reform Act is to be enforced as if it were in compliance with the act, irrespective of its actual terms. Andriakos v. Cavanaugh, 350 So. 2d 561 (Fla.2d DCA 1977). If a government-owned vehicle is a “motor vehicle” within the scope of Florida’s Automobile Reparations Reform Act, then the State Farm policy exclusion that excluded insureds from coverage while they were in government vehicles was in violation of Florida’s Automobile Reparations Reform Act. The term “motor vehicle” is defined in the act in section 627.-732(1). The statutory definition does not exclude government vehicles.
The section of the act dealing with proof of security excludes government vehicles from all sections of the act. § 627.734(3), Fla.Stat. (1981). This statute was intended to exempt governmental bodies from having to obtain no-fault coverage on vehicles that they own and was not intended to take government vehicles out of the definition of “motor vehicles.” Therefore, Rule 4-27.01, Rules of the Department of Insurance, which defines motor vehicles, is in conflict with the statutory definition.
In a declaratory judgment action, a trial court may enter a judgment on the pleadings if the merits of the case can be determined as a matter of law from the pleadings. Trail Burger King, Inc. v. Burger King of Miami, Inc., 187 So. 2d 55 (Fla.3d DCA 1966). In the case at hand, the trial court did not declare that Chapman was entitled to any specific amount of benefits, but rather the trial court only declared that Chapman was entitled to personal injury protection coverage. The coverage issue was a proper issue for the trial court to resolve with a declaratory judgment. Britt v. Fidelity & Casualty Co., 360 So. 2d 116 (Fla.3d DCA 1978); Tavares v. Allstate Ins. Co., 342 So. 2d 551 (Fla.3d DCA 1977).
The Florida Supreme Court recently has reaffirmed the validity of the Florida Automobile Reparations Reform Act. Chapman v. Dillon, 415 So. 2d 12 (Fla.1982).
Accordingly, the judgment of the trial court is
AFFIRMED.
ORFINGER and FRANK D. UP-CHURCH, Jr., JJ., concur.
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The Travelers Ins. Co. v. Emery, 579 So. 2d 798 (Fla. 1st DCA 1991)…. . See Prudential Property & Casualty Ins. Co. v. Castellano, 571 So. 2d 598 (Fla. 2d DCA 1990); Tindall v. Allstate Ins. Co., 472 So. 2d 1291 (Fla. 2d DCA 1985), review denied, 484 So. 2d 10 (Fla. 1986); State Farm Mut. Auto. Ins. Co. v. Chapman, 415 So. 2d 47 (Fla. 5th DCA 1982), review denied, 426 So. 2d 29 (Fla.1983); United Servs. Auto. Ass’n v. Setchfield, 384 So. 2d 34 (Fla. 2d DCA 1980) (since the validity and effectiveness of the endorsement or instrument allegedly terminating the insurance contra…
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Mr. & Mrs. Dale Appel v. Scott, 479 So. 2d 800 (Fla. 2d DCA 1985)…ses which hold that a court may enter a final adjudication on the pleadings in a declaratory judgment action where the merits of the case can be determined as a matter of law from the pleadings. State Farm Mutual Automobile Insurance Co. v. Chapman, 415 So. 2d 47, 49 (Fla. 5th DCA 1982), petition for review denied, 426 So. 2d 29 (Fla.1983); Trail Burger King, Inc. v. Burger King of Miami, Inc., 187 So. 2d 55, 57 (Fla. 3d DCA [*804] 1966). However, that rule is applicable only where the moving party is clearl…
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Camino Gardens Ass'n, Inc. v. McKIM, 612 So. 2d 636 (Fla. 4th DCA 1993)…n this declaratory judgment action. “In a declaratory judgment action, a trial court may enter a judgment on the pleadings if the merits of the case can be determined as a matter of law from the pleadings.” State Farm Mut. Auto. Ins. Co. v. Chapman, 415 So. 2d 47, 79 (Fla. 5th DCA 1982), petition for review denied, 426 So. 2d 29 (Fla.1983). An evidentiary hearing need not be held in every case prior to the grant of a motion for judgment on the pleadings. In ruling on a motion for judgment on the pleadings, “…
Previewing 3 of 6 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Chapman v. Dillon, 415 So. 2d 12 (Fla. 1982)
- Tavares v. Allstate Ins. Co., 342 So. 2d 551 (Fla. 3d DCA 1977)
- Trail Burger King, Inc. v. Burger King OF Miami, Inc., 187 So. 2d 55 (Fla. 3d DCA 1966)
- Wilson v. State, 350 So. 2d 561 (Fla. 2d DCA 1977)
- Britt v. Fid. & Cas. Co. of N.Y., 360 So. 2d 116 (Fla. 3d DCA 1978)