Ogden v. United States Fidelity & Guarantee Co

In Ogden v. United States Fidelity & Guarantee Co., 188 Ariz. 132, 134-35, 933 P.2d 1200, 1202-03 (App. 1996), an employee had been involved in a motor vehicle accident while driving a truck he had purchased from his employer that was ostensibly covered by the employer's insurance policy. The insurance policy, however, excluded vehicles owned by employees. Id. at 134, 933 P.2d at 1202. The injured parties argued the exclusion was invalid under the reasonable expectations doctrine. Id. at 138, 933 P.2d at 1206. Although the employer had promised "to provide insurance for the vehicle," Division One of this court determined the employee's "expectations have little effect on the enforceability of a contract of insurance" to which the employee was not a party. Id. at 138-39, 933 P.2d at 1206-07. Instead, Division One considered the reasonable expectations of the employer that had purchased the policy. Id. at 139, 933 P.2d at 1207.