What happened: A Georgia appeals court reversed an insurer's denial of uninsured motorist coverage for a county-owned tractor
Who's involved: AmGUARD Insurance Company and a Jenkins County road department worker
What's at stake: UM benefits for serious injuries from a highway collision
Why it matters: The policy's own coverage code - not the vehicle schedule - determined which autos qualified for UM protection
Where it stands: Unanimously reversed on November 2, 2026; case sent back to trial court
The county worker was mowing the shoulder of Georgia Route 67 on a Kubota tractor when he was seriously injured in a collision. When he sought uninsured motorist benefits under the county's commercial auto policy, the insurer said the tractor wasn't covered - it wasn't on the vehicle list.
A Georgia appeals court just said the insurer was reading its own policy wrong.
The Court of Appeals of Georgia unanimously reversed AmGUARD Insurance Company on November 2, 2026, after finding that the insurer's own policy language extended UM coverage to the unlisted tractor. The case turned on a detail buried in the policy's coverage structure: a single numeric code.
AmGUARD insured Jenkins County under a commercial auto policy with a UM endorsement. The policy included a "Schedule of Autos" - a roster of covered vehicles listed by make and VIN. The Kubota wasn't on it.
AmGUARD asked the court to rule in its favor without a trial, arguing the tractor's absence from the schedule settled the question. The trial court agreed, finding that the policy "unambiguously [did] not provide UM coverage for the Kubota tractor."
But the policy had a second schedule - a "Schedule of Coverages and Covered Autos" - that used numeric codes to designate which vehicles qualified for each type of coverage. For most coverages, the code was "7," meaning only vehicles specifically listed by make and VIN. For UM coverage, the code was "2," meaning all vehicles owned by the policyholder.
That one digit changed everything. Code "2" covered any auto the county owned, whether or not it appeared on the vehicle list. The Kubota was county property.
AmGUARD had a fallback. Georgia law exempts tractors "used only for agricultural purposes" from registration and insurance requirements. If that exemption applied, the Kubota wouldn't qualify as an insurable "auto" under the policy at all.
The court wasn't persuaded. The worker was an employee of the Jenkins County Road Department, mowing grass along the side of a public highway. That is road maintenance, not farming.
Georgia's highest court had already held that "a farm tractor can be an uninsured motor vehicle for purposes of the uninsured motorist statute when, in the course of a nonagricultural pursuit, it collides with another vehicle on a public highway." The appeals court applied that reasoning directly.
The reversal sends the case back to the trial court. The appeals court found the policy "unambiguously" provides UM coverage for county-owned autos and that the Kubota qualifies. All three judges agreed.
For commercial auto underwriters and claims teams reviewing UM exposure on public-entity accounts, the case is a practical flag: coverage codes in the policy schedule - not the vehicle roster - define which units carry UM protection. A vehicle left off the list may still be fully covered if the UM code designates a broader class.
The ruling was issued by the Court of Appeals of Georgia on November 2, 2026. It reflects the court's interpretation of AmGUARD's policy language and Georgia's UM statute. No further appellate proceedings are noted in the decision.
