August 26, 2019

The Pennsylvania Supreme Court has ruled unanimously that unregistered driver exclusions in auto insurance policies do not violate public policy or the Pennsylvania Motor Vehicle Financial Responsibility Law (PMVFR). The case is Safe Auto Insurance v. Oriental-Guillermo, 7 Cal. 5th 781 (2019).

In April 2013, Rachel Dixon was driving a car owned by her live-in boyfriend Rene Oriental-Guillermo and was involved in a two-car accident. A passenger in the other vehicle sued, but Safe Auto pursued a declaratory judgment action in order to determine whether it had to pay out on the policy or if the policies unregistered driver exclusion applied in this situation. Safe Auto subsequently filed a motion for summary judgment arguing that because Dixon was unrelated to Oriental-Guillermo and was also not listed as a household member on the policy, Safe Auto had no duty to defend or indemnify her. The trial court granted that motion.

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