State Farm and GEICO have escaped a Georgia uninsured motorist claim after an appeals court ruled policy wording shut the door on both.
On May 20, 2026, the Court of Appeals of Georgia reversed a trial court that had let Charity Barnor-Cooper's personal injury case move forward against the two insurers. The win for the carriers turned on two pieces of policy language – one about a sold vehicle, the other about peer-to-peer car-sharing through Turo.
Barnor-Cooper was hurt in a hit-and-run while making a delivery for her husband's company, Coopers TR, LLC. She was driving a Buick she had rented through Turo at the time. She sought uninsured motorist benefits from State Farm, which had issued a policy to Coopers TR, and from GEICO, which insured the Buick.
Against State Farm, she argued the Buick should count as a temporary substitute car because mechanical issues with the Dodge Caravan listed on the policy had pushed her into the rental. The court did not buy it. The Dodge had already been sold by the time of the crash. Under the policy, a temporary substitute car had to step in for a covered vehicle – and the policy explicitly said a covered vehicle did not include any car the named insured no longer owned or leased. With the Dodge gone, there was nothing left to substitute for.
She also argued she was effectively the named insured because Coopers TR was just a trade name for her husband, who owns the company. The court disagreed, pointing out that an LLC is a separate legal entity from its owners and can be the true named insured on its own.
Her estoppel argument – that State Farm could not deny coverage because it had kept accepting premiums on the Dodge – went nowhere. She offered no evidence the insurer knew the Dodge had been sold when it took those payments.
The GEICO ruling came down to a peer-to-peer car-sharing exclusion. The policy ruled out uninsured motorist coverage for any vehicle used as part of personal vehicle sharing facilitated by a personal vehicle sharing program, which the policy defined as a business, organization, network or group facilitating the sharing of private passenger vehicles for individuals or businesses.
Barnor-Cooper testified she rented the Buick through Turo. She argued that when she arrived to pick up her reserved car, the owner gave her a different vehicle – the Buick – so her use of it was not really facilitated by a car-sharing program. The court was not convinced. Her rental was still booked and paid for through Turo, and even reaching for a dictionary definition of "facilitate," the court said the platform clearly made the rental happen.
The court also rejected her argument that the exclusion clashed with Georgia law. State law, the court said, lets motor vehicle liability insurers exclude coverage - including uninsured motorist coverage – for any claim falling under a shared vehicle owner's policy, citing OCGA § 40-1-223(a)(3).
Both judgments were reversed.
