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Allstate Ins. Co. v. Spillers

The trial court erred in basing its judgment for defendant on its finding that defendant reasonably believed he had permission to use an insured vehicle, rather than considering whether a reasonable person could conclude under the circumstances that the use of the insured vehicle fell within the policy holder's permission.

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In this declaratory judgment action, Allstate Insurance Company “Allstate” appeals from the trial court’s ruling that, since Randall Spillers had implied permission to use an insured car at the time of a car accident, Allstate was obligated to provide insurance coverage to Spillers for injuries arising out of the accident. Since the incorrect legal standard was applied by the trial court, we must vacate the trial court’s ruling and remand the case for consideration under the proper legal standard.

Spillers purchased a 1987 Ford Mustang in 1995. After having his license suspended and facing various financial issues, Spillers fell behind on the car payments. In order to avoid having the car repossessed, Spillers’s father agreed to refinance the car and to take over the payments while Spillers repaid him directly. Spillers’s father believed that taking over the payments would place the title to the car in his name, but the title was never transferred and remained in Spillers’s name.

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