Lancer Insurance Company v Lakeshore Motor Coach Lines, Inc.

The United States District Court for Utah certified a question to the court asking if Utah Code 31A-22-301(1), which imposes a coverage requirement for when a driver unexpected loses consciousness, imposes strict liability or if it is subject to the sudden incapacity defense. The Court held that the statute imposes strict liability reasoning that holding otherwise would deprive the statute of independent meaning and render it superfluous and noting the statute uses “driver’s liability” in setting out limits on coverage which is nonsensical if the sudden incapacity defense applied and set liability at $0. The court also held that the statute limits liability to the amount of coverage under the plain language. It emphasized that its holding here is limited to situations where there is coverage and left open the issue of whether the sudden incapacity defense remains good law in other situations.