Kentucky Court of Appeals says helmet is not integral part of motorcycle in accident dispute
by Mandy Hicks
The Kentucky Court of Appeals has ruled in an unpublished opinion that a helmet is not an integral part of a motorcycle for purposes of uninsured motorist benefits. This issue was decided on in the case of Stallard v. State Farm Mut. Auto. Ins. Co. The case involved a motorcycle owner who was injured in an accident while riding with a group of other bikers. The man was riding in the center of a group of about two dozen motorcyclists when the group of riders suddenly slowed. As the man attempted to avoid an accident with another motorcycle, he sustained serious injuries when another motorcyclist’s unsecured helmet bounced into his tire.
When the motorcycle accident occurred, the motorcyclist carried uninsured motor vehicle (UM) insurance. Since the injured man was not hit by another vehicle, however, the motorcyclist’s insurer denied his insurance benefits claim. After that, the injured rider filed a lawsuit against his insurance carrier in Jefferson County Circuit Court.
In response, the insurer filed a motion for summary judgment, claiming it was not required to provide benefits under the terms of the policy because the motorcyclist was not physically struck by another vehicle, nor was he injured by an integral part of another vehicle. The hurt rider countered that he should be compensated by his UM insurer because a motorcycle helmet is an integral part of a motorcycle. The trial court sided with the insurance company and granted summary judgment in favor of the insurance carrier.
The motorcyclist appealed the case to the Kentucky Court of Appeals, which stated that the facts of the case were not in dispute.
The court relied on another Uninsured Motorist Case decided by the Kentucky Supreme Court, State Farm Mutual Insurance Company vs. James Baldwin and Ronda Reynolds vs. Safeco. Insurance Company of Illinois. That case addressed the same UM policy language at issue in the case at hand. In Baldwin, the high court stated UM coverage is only available when an uninsured vehicle or an integral part of an uninsured vehicle physically strikes an insured individual’s vehicle or such a vehicle “projects a force in a chain reaction accident.”
According to the Court of Appeals, another vehicle clearly did not hit the injured rider. In addition, the Supreme Court specifically stated in Baldwin that chain reaction liability only occurs when an uninsured land vehicle “projects a force on another object which then hits the insured’s vehicle.” The high court added that coverage does not apply when a non-integral part of an uninsured vehicle becomes loose and strikes an insured’s motor vehicle.
The appellate court found that the helmet was not an integral part of the uninsured motorcycle. The Court affirmed the lower court’s decision and held that motorcyclists are not legally required to wear helmets in the Commonwealth of Kentucky. The court added that a helmet is not a factory-installed essential component nor is it a permanently or even a semi-permanently installed fixture on a bike.
Since the injured man provided the court with no evidence demonstrating that he was entitled to UM benefits under the terms of his insurance policy, the Kentucky Court of Appeals affirmed the Jefferson County Circuit Court’s order granting summary judgment in favor of his insurer.
If you were injured in a motorcycle or other traffic wreck in Kentucky, you should discuss your rights with a quality Bowling Green personal injury lawyer as soon as possible. To schedule a free confidential consultation with a skilled attorney, call English, Lucas, Priest & Owsley, LLP at (270) 781-6500 or contact us through our website.
Stallard v. State Farm Mut. Auto. Ins. Co., Ky: Court of Appeals 2015