Cookson v. Liberty Mutual Fire Ins. Co

In Cookson v. Liberty Mutual Fire Ins. Co., 2012 ME 7, 34 A3d 1156 [Me. 2011], the Court found that a tractor, occasionally driven on the public highway, was subject to motor vehicle registration based on the type of vehicle it was and not on whether it would actually be registered. The Court noted that the relevant Maine statute "provides for the registration of tractors and therefore it did not fall within the exclusion's exception." In dicta the Court then stated that the tractor was not the type of machine "commonly employed" by the average homeowner in servicing his or her residence. However, Cookson involved a property damage claim by the insured after his tractor was destroyed in a fire, and there is no indication in the reported facts that the insured used the tractor for anything other than construction of a residence on his property.