Defence & Indemnity - December 2016: I. INSURANCE ISSUES B.

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A vehicle owned by the insured or spouse, if insured, may be an “uninsured automobile” when taken without consent and therefore may be entitled to coverage under the O.P.C.F. 44R Endorsement as an “inadequately insured motorist”, notwithstanding that one part of the definition of “uninsured automobile” excludes an automobile owned by or registered in the name of the insured or his or her spouse. 

Skunk v. Ketash, 2016 ONCA 841, per Hoy A.C.J.O.

Mr. Skunk was a passenger in a motor vehicle owned by his spouse, Mrs. Skunk, but driven by a friend of his, Ms. Ketash, when a motor vehicle accident occurred. Mr. Skunk took the position that Ms. Ketash was driving Mrs. Skunk’s vehicle without her consent.
In addition to suing Ms. Ketash, Mr. Ketash commenced an action against Jevco Insurance Company, Mrs. Skunk’s insurer, pursuant to s. 265 of the Insurance Act R.S.O. 1990 c. I.8, and the standard Ontario Automobile Policy OPA 1 (the “Policy”) and the optional OPCF 44R Family Protection Coverage Endorsement (the “Endorsement”) issued to his spouse.
In suing Jevco, Mr. Skunk sought to recover under the uninsured provisions in the Policy and Endorsement issued to his spouse, the owner of the vehicle driven by Ms. Ketash.  Jevo applied to the Court for summary judgment, the summary judgment motion was dismissed by the motions judge.
Jevco appealed the dismissal of its summary judgment motion to the Court of Appeal. It submitted that the motion judge made a final determination of law that was wrong and which would be binding on the trial judge.
The issue arose whether the motions judge made an interlocutory or final order with respect to the determination of whether a vehicle owned by the insured or spouse, if insured, is a “uninsured automobile” when taken without consent and therefore entitled to coverage under the O.P.C.F. 44R Endorsement as an “inadequately insured motorist”, notwithstanding that one part of the definition of “uninsured automobile” excludes an automobile owned by or registered in the name of the insured or his or her spouse.
The owner of a motor vehicle is liable for accidents caused by its operation under s. 192 of the Highway Traffic Act, R.S.O. 1990, c. H.8, (the Act) except where subsection (2) applies, which provides as follows:

The owner of a motor vehicle or street car is liable for loss or damage sustained by any person by reason of negligence in the operation of the motor vehicle or street car on a highway, unless the motor vehicle or street car was without the owner’s consent in the possession of some person other than the owner or the owner’s chauffeur. [Emphasis Added].

The term “uninsured automobile” is defined in the Standard Ontario Automobile Policy – O.A.P. No. 1 in Subsection 5.1.2 under Uninsured Automobile Coverage:

5.1.2 What is an Uninsured Automobile?
An uninsured automobile is one for which neither the owner nor driver has liability insurance to cover bodily injury or property damage arising out of its ownership, use or operation, or the insurance is not collectible. However, this does not include an automobile owned by or registered in the name of the insured person or their spouse. [Emphasis Added].

The term “inadequately insured motorist” and “uninsured automobile” are defined in the O.P.C.F. 44R Endorsement under Section 1 as:
1.5 “inadequately insured motorist” means

(a) the identified owner or identified driver of an automobile for which the total motor vehicle liability insurance or bonds, cash deposits or other financial guarantees as required by law in lieu of insurance, obtained by the owner or driver is less than the limit of family protection coverage; or


(b) the driver or owner of an uninsured automobile or unidentified automobile as defined in Section 5, “Uninsured Automobile Coverage” of the Policy.

1.11 “uninsured automobile” means an automobile with respect to which neither the owner nor driver thereof has applicable and collectible bodily injury liability and property damage liability insurance for its ownership, use or operation but does not include an automobile owned by or registered in the name of the insured or his or her spouse. [Emphasis Added].

III. HELD: Appeal quashed for lack of jurisdiction, the motion judge’s order was interlocutory and did not extend coverage to the Plaintiffs pursuant to the O.P.A. 1. Endorsement

1. The Court held that the Motion Judge did not make a final determination of law and quashed the appeal as the order under appeal was not a final order.
a. The Court held that the below excerpt, provided by the motion judge at paragraph 34, is not a final determination of law:

“I therefore conclude that vehicles owned by the insured or spouse, if insured, are “uninsured automobiles” when taken without consent. Therefore, I conclude that Ms. Ketash, if she took the vehicle without consent, is an “inadequately insured motorist” under the [Endorsement].
As such, I conclude that there may be coverage and Jevco’s motion for summary judgment is dismissed. [Emphasis added]”
b. The motion judge disagreed with Quinn J.’s conclusion in Fosker v. Thorpe, 2004 CanLII 33358 (ON SC), 72 O.R. (3d) 753 (S.C.), that s. 265(2) of the Insurance Act, s. 5.1.2 of O.A.P. No.  1 and O.P.C.F. 44R are clear and unambiguous. In Fosker, a thief, in the course of stealing the plaintiff’s car, struck the plaintiff with her own car. The Court held that because the car was owned by the insured plaintiff, it was not an “uninsured automobile.”
To the contrary, the motion judge in this case, applying principles of contractual, rather than statutory, interpretation to the Endorsement, concluded that those provisions were also ambiguous and accordingly should be construed against Jevco and given an “interpretation that spreads, rather than closes, the safety net” (paragraph 30.)

Here, the Court of Appeal did not draw a conclusion on the correctness of the motion judge’s above determination.

c. Despite expressing a “conclusion” about the interpretation of the Endorsement in his reasons, the motion judge simply determined that there “may” be coverage. The Court of Appeal said it was not clear that the motion judge did not simply conclude that there was a genuine issue for trial as to whether or not Mr. Skunk is entitled to coverage. As such, the Court of Appeal held that there was no binding determination of law.
[51]      Jevco argues that the motion judge used the word “may” in his reasons because, albeit mistakenly, he thought that the issue of whether or not the vehicle was driven without the consent of Ms. Skunk would be a live issue at trial. Jevco points to the motion judge’s use of the word “if” at para. 34: “Therefore, I conclude that Ms. Ketash, if she took the vehicle without consent, is an ‘inadequately insured motorist’.”

[52]      At paragraph 3 of his reasons, the motion judge wrote that “the vehicle … became uninsured when it was taken without consent by the defendant Ketash.” However, after reciting the facts as recounted in Mr. Skunk’s factum, the motion judge wrote the following phrase, at paragraph 11, giving rise to Jevco’s argument:  “On these facts, it is not clear that there is a lack of consent.”

[54]      Jevco’s explanation of why the motion judge used the words “if” and “may” is plausible. However, the motion judge’s reasoning is unclear.  Another plausible explanation is that the motion judge understood that the question of consent was not an issue for trial and used the word “if” because he did not want to appear to endorse what the parties had agreed amounted to lack of consent.  And, if that interpretation is accepted, then “may” is consistent with his determining only that there is a genuine issue for trial.  Given this ambiguity in the motion judge’s reasons, his conclusions should not be taken as anything more than his explanation for finding that there is a genuine issue for trial.

2. The Court, in obiter, highlighted some “applicable insurance principles” regarding section 265(2) of the Insurance Act, section 5.1.2 of O.A.P. No.  1 and O.P.C.F. 44R.

a. The Compulsory Automobile Insurance Act, R. S. O. 1990, c. 25. provides for compulsory automobile insurance in Ontario. The purpose of this legislation is to protect victims of automobile accidents “from having no means of seeking damages from persons who might have caused those damages without having the protection of automobile insurance”: Matheson v. Lewis, 2014 ONCA 542 (CanLII), 121 O.R. (3d) 641, at paragraph 36.
b. The purpose of s. 192(2) of the Highway Traffic Act, R.S.O. 1990, c. H.8,  was noted in Fernandes v. Araujo2015 ONCA 571 (CanLII), 127 O.R. (3d) 115 (C.A.), at paragraph 20:
The purpose of this provision is "to protect the public by imposing, on the owner of a motor vehicle, responsibility for the careful management of the vehicle". The provision is an integral element of the Highway Traffic Act's mandatory licensing and insurance scheme to ensure the public safety. The owner has the right to give possession of the vehicle to another person, but this provision "encourages owners to be careful when exercising that right by placing legal responsibility on them for loss to others caused by the negligent operation of the vehicle on a highway."
c. The Court explained at paragraph 10 that, if the motor vehicle is driven by a person who has the owner’s consent and is involved in an accident, section 3.2 of the OAP provides coverage: “You are covered when you, or anyone else in possession of a described automobile with your consent, uses or operates it. We will consider these other people insured persons.”
[11]     In the normal course, if a person is injured by the operation of the motor vehicle in which he or she is a passenger, the vehicle owner’s insurer must respond.
[12]     But some owners fail to insure their automobile, or their insurance is voided, and so the automobile is not insured. The Insurance Act mandates a scheme to provide for limited insurance coverage where the operation of an uninsured automobile injures a person. The coverage is provided by the injured person’s own insurer, but coverage is limited to the minimum required by s. 251 of the Insurance Act, which is $200,000 for liability claims.

[13]     In order to mitigate the consequences of being injured by an uninsured or underinsured motor vehicle, purchasers of automobile insurance policies in Ontario can buy, for an additional premium, added coverage in the form of the OPCF 44R Family Protection Coverage Endorsement.

3. The general rule is that an order dismissing a motion for summary judgment is an interlocutory and not a final, order.

a. Consistent with the Court of Appeals directions in Ashak v. Ontario (Director, Family Responsibility Office), 2013 ONCA 375 (CanLII), 115 O.R. (3d) 401, in the absence of an express indication by the motion judge that her determination is to be binding on the parties at trial, it should be presumed that in expressing a conclusion on a point of law when dismissing a summary judgment motion she is simply explaining why she concluded that there is a genuine issue requiring a trial, and did not intend her determination to be binding on the parties.
[30]      Subject to certain exceptions – none of which are relevant in this case an appeal lies to this court from a final order of a judge of the Superior Court of Justice. If an order is interlocutory, rather than final, the appeal lies to the Divisional Court, with leave: Cole v. Hamilton (City), 2002 CanLII 49359 (ON CA), 60 O.R. (3d) 284 (C.A.), at para. 15; Albert v. Spiegel, 17 C.P.C. (3d) 90 (Ont. C.A.), at p. 91.
[36]      At paragraphs 11 and 13 of Ashak, the court wrote:
“It is our view that, if a motion judge dismissing a motion for summary judgment proposes to exercise the power under rule 20.04(4)[[1]] to make a binding determination of law, the motion judge should specifically invoke the rule, and reference to the rule, as well as the legal determination made, should form part of the formal order. In our opinion, the issue of whether an order is final or interlocutory should not turn on the forcefulness of the reasons for the conclusion….”

b. While the court may take into account a party’s concession that an issue is or is not res judicata (a matter that has been adjudicated by a competent court and may not be pursued further by the same parties), in determining whether an order is final or interlocutory, a concession cannot confer or deprive the court of jurisdiction.

IV. COMMENTARY: The comments in the case regarding the application of the section 265(2) of the Insurance Act, section 5.1.2 of Ontario Automobile Policy, and the Endorsement are obiter and therefore not binding, however they do provide insight into the Court’s interpretation of said. It appears, according to the comments of the motion judge, that vehicles owned by the insured or spouse, if insured, may be “uninsured automobiles” when taken without consent. Therefore, the driver, if she or he took the vehicle without consent, may be an “inadequately insured motorist” under the Endorsement.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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