The case of Mazur v. State Farm Mutual Automobile Insurance Company revolves around a dispute over underinsured motorist (UIM) coverage following a car accident that occurred on April 14, 2021. The plaintiffs, Stephanie Mazur and Julia Wunder, were driving a 1999 Toyota Land Cruiser insured by State Farm when an incident involving a pedestrian on Interstate 25 led to their vehicle rolling over and causing injuries. The plaintiffs sought UIM coverage from State Farm, which was subsequently denied, prompting the lawsuit.
At the time of the accident, Thomas and Melinda Wunder owned and insured the Land Cruiser under a policy with State Farm that included UIM coverage. The policy stipulated that State Farm would compensate for bodily injury sustained by an insured individual if the injury was caused by an accident involving the "operation, maintenance, or use of an uninsured motor vehicle."
The chain of events leading to the accident began when Richard Fralick's Subaru broke down on the northbound lanes of Interstate 25 in New Mexico. Fralick moved the vehicle to an emergency crossover between the northbound and southbound lanes. His passenger, William Westuk, later left the vehicle and attempted to flag down motorists on the southbound lanes. As Mazur approached in the Land Cruiser, she swerved to avoid Westuk, lost control, and the vehicle rolled multiple times, injuring both plaintiffs.
Following the accident, Mazur and Wunder filed UIM claims with State Farm, arguing that their injuries were caused by Fralick’s negligent operation and maintenance of the Subaru. State Farm denied the claims, asserting that the accident did not involve the "operation, maintenance, or use" of the Subaru as a motor vehicle under the terms of the policy.
The primary legal question in the case was whether the accident fell within the scope of UIM coverage under the State Farm policy. Specifically, the court analyzed whether the accident was "caused by an accident that involves the operation, maintenance, or use of an uninsured motor vehicle."
Under Colorado law, as interpreted in State Farm Mut. Auto. Ins. Co. v. Kastner, the use of a motor vehicle must be inherent to its purpose and must be causally related to the injury. The court applied a two-pronged test:
The court determined that Westuk’s actions—leaving the Subaru and attempting to stop southbound traffic—were not a foreseeable or inherent use of a vehicle as defined under the policy. Additionally, even if the breakdown of the Subaru was considered an inherent use, Westuk’s independent actions in entering the southbound lanes constituted a significant intervening event that broke the causal chain.
The court granted summary judgment in favor of State Farm, ruling that the insurer had no obligation to cover the plaintiffs' injuries under the UIM policy. It found that Westuk’s actions were not a covered "use" of the Subaru, and even if they were, his decision to enter the highway independently interrupted any direct causal link between the uninsured vehicle and the plaintiffs' injuries. Consequently, the court dismissed the plaintiffs' breach of contract, bad faith, and statutory violation claims.
The decision in Mazur v. State Farm underscores the importance of precise policy language and reinforces the principle that insurance coverage is bound by its contractual definitions rather than broader notions of fairness or need
