In Dougherty v. State Farm Mut. Ins Co., No. A03-1866, 2005 WL 1645631 (Minn. July 14, 2005), the Supreme Court of Minnesota ruled that a driver of a vehicle who was injured walking home after her car was stranded in a snowdrift suffered injuries arising out of the maintenance or use of a vehicle.
Sheryl Dougherty left a bar after a night of drinking and attempted to drive home. Her car became stuck in a snowdrift, and she decided to walk home. The temperature was minus forty-five degrees Fahrenheit. She had to use her arms and hands to push her way though a snow bank. She slipped and fell on some ice, crawled on the ice, took refuge near a garage, and may have fallen asleep. She suffered severe frostbite from the incident, and some of her fingers were amputated as a result.
Dougherty sought no-fault benefits from her insurer, State Farm. State Farm denied the claim, stating that the injuries did not arise out of the maintenance or use of a motor vehicle, as required by Minnesota's no-fault law.
The court identified three factors for determining if an accident arose out of the maintenance or use of a motor vehicle:
1. the extent of causation between the automobile and the injury;
2. whether an act or independent significance occurred, breaking the causal link between “use” of the vehicle and injuries inflicted; and
3. whether the automobile was being used for transportation purposes.
The court further stated, “A causal connection between the injury and the maintenance or use of a motor vehicle is established if 'the injury is a natural and reasonable incident or consequence' of the vehicle's use…the vehicle must have been an 'active accessory' in causing the injury.”
State Farm argued that Dougherty encountered premises hazards that caused her injuries, not maintenance or use of her vehicle. She was exposed to the elements for an extended period of time, State Farm contended, due to the icy parking lot and snowdrifts.
Dougherty countered that her encounter with the dangerous weather conditions was not “a situation wholly dissociated from and unrelated to her use of her vehicle.” She said that getting stuck in the snow and being stranded are risks associated with driving.
The court concluded that “the requisite causal connection between Dougherty's injuries and her use of the vehicle is established because it is a 'natural and reasonable incident or consequence' of the use of a vehicle in Minnesota in the winter that a vehicle may become lodged in a snowdrift and the driver may attempt to seek safety, as Dougherty did here.”
State Farm also claimed that Dougherty was intoxicated, which broke the chain of causation between the use of the vehicle and the injuries she suffered. However, Minnesota's no fault law, the court pointed out, insurers must pay benefits regardless of fault. Driving under the influence, while a criminal offense, is not excluded by the no-fault law. Thus, the chain was not broken.