Insurance Coverage Extended to Those with “Some Connection” to the Vehicle
State Farm Mut. Ins. Co. v. Mizuno (HSC November 20, 2020) Background. Michael Mizuno borrowed his girlfriend’s car to run errands. He drove the vehicle to the post office to mail paid bills. He was in the crosswalk between the vehicle and the post office when he was hit and injured by an unidentified driver. The vehicle drove away. Mizuno sought uninsured motorist coverage from his girlfriend’s policy. State Farm, the insurance company, filed a motion for declaratory judgment in federal court. The U.S. District Court granted summary judgment for State Farm and determined there was no coverage under Hawai'i law for Mizuno. Mizuno appealed to the Ninth Circuit. The appellate court was unsure how far to extend Hawai'i law in this area and certified the question to the HSC. The Uninsured Motorists Statute and the Chain-of-Events Test. “[A]ny motor vehicle registered or principally garaged in this State” must have liability coverage “for the protection of persons insured...