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Insurance Coverage / CT Court Grants Insurer Summary Judgment in Uninsured Motorist Claim

Insurance Coverage: Court grants insurer’s motion for summary judgment upon finding that plaintiff will be unable to prove his injuries were caused by the negligence of the unidentified motorist, as required under the express language of the plaintiff’s insurance policy:

The defendant, Amica Mutual Insurance Company, moves for summary judgment as to count one of the plaintiff’s complaint on the grounds that no genuine issue of material fact exists as to the plaintiff’s inability to prove his injuries were caused by the negligence of an unidentified motorist, as necessary to establish a claim for uninsured motorist benefits under the plaintiff’s insurance policy. The plaintiff alleges that he was operating his motor vehicle northbound on Interstate 91 when a metal object detached from an unidentified motor vehicle, disabling a vehicle in the left lane directly in front of the plaintiff’s vehicle, causing the plaintiff to evade the disabled vehicle and resulting in a three-vehicle collision. The collision, the plaintiff alleges, was caused by the negligence of the unidentified tortfeasor from whose vehicle the metal object detached. At the time of the accident, the plaintiff was insured by Amica. In its motion for summary judgment, Amica specifically argues that there is no question of material fact that the plaintiff cannot prove (1) the “metal object” came from a non-contact, unidentified vehicle, (2) the “metal object” “detached” from a non-contact, unidentified vehicle, because of a negligent act, (3) any driver of an alleged non-contact, unidentified vehicle was negligent and/or (4) any negligence by a driver of an alleged non-contact, unidentified vehicle caused the accident. The plaintiff objected, and the court heard oral argument on the issue. In entering its decision, the court finds undisputed that in order to recover, the express terms of the plaintiff’s policy clearly and unambiguously require him to establish that his injuries were the result of the negligence of the unidentified motorist. In reviewing the Amica’s evidence, the court holds that Amica demonstrated the plaintiff cannot sustain his contractual burden. The operator of one of the other involved motor vehicles testified that he had no knowledge as to why the vehicle was disabled and came to a stop on the highway. The co-defendant operator similarly had no knowledge as to why the vehicle became disabled nor any awareness of the existence of any metal object. Further, one of the responding Connecticut State Troopers testified that although he observed a metal object under the disabled vehicle, he could not provide any factual basis for its origin nor could he identify the object. Significantly, the State Trooper was unable to even identify the metal object as a car part. Lastly, the plaintiff himself admitted he did not personally observe the vehicle becoming disabled from a piece of metal detaching from another vehicle. The only evidence presented by the plaintiff that a metal object may have been in any way associated with an unidentified non-contact vehicle was a statement made by the operator of the disabled vehicle captured on the State Trooper’s body camera footage. When asked what happened, the operator of the disabled vehicle stated, “something fell out of a truck.” Even considering this statement, the court finds it insufficient to defeat summary judgment. The statement made by the operator of the disabled vehicle does not contain any specific description of the “something” that fell out of the truck nor did the operator make any statement that something “detached” from the truck, as alleged by the plaintiff. Because Amica met its burden of establishing the absence of any genuine issue of material fact surrounding the plaintiff’s inability to sustain his contractual burden of proving his injuries were caused by the negligence of an unidentified motorist, the court holds that Amica is entitled to judgment as a matter of law and grants Amica’s motion for summary judgment. Rich v. Amica Mutual Ins. Co., Docket No. HHD-CV-23-6166760-S, 2026 Conn. Super. LEXIS 475 (Super. Mar. 10, 2026).