Key Takeaway
Fourth Department ruling establishes triable issue of fact regarding vehicle ownership despite conflicting documentation and testimony in no-fault insurance case.
Vehicle ownership disputes frequently arise in New York No-Fault Insurance law cases, particularly when determining who qualifies for benefits or coverage. The question of ownership becomes especially complex when official documentation conflicts with actual financial responsibility and use patterns. A recent Fourth Department decision illustrates how courts handle these competing claims when determining whether a genuine issue of material fact exists regarding vehicle ownership.
The case demonstrates the legal principle that registered ownership creates a rebuttable presumption, but parties can present evidence to challenge that presumption. This becomes particularly relevant in family situations where multiple individuals may have financial stakes in a vehicle, even though only one person appears on official documents. Such disputes often require careful examination of payment records, insurance arrangements, and testimony about actual ownership arrangements.
Jason Tenenbaum’s Analysis:
Harris v Direct Gen. Ins. Co., 2017 NY Slip Op 08961 (4th Dept. 2017)
(1) “We have previously stated that, generally, ownership is in the registered owner of the vehicle or one holding the documents of title, but a party may rebut the inference that arises from these circumstances”
(2) “defendant submitted plaintiff’s testimony that he was the co-owner of the vehicle, and that he and his fiancée paid for the vehicle, its maintenance, and a Florida insurance policy that did not cover plaintiff. Nevertheless, defendant also submitted the registration, title, and insurance documents for the vehicle, all of which list plaintiff’s father as the owner. ”
Courts found a triable issue of fact as to whether Plaintiff owned the vehicle. Makes sense to me. The matter should go to trial.
Key Takeaway
When determining vehicle ownership for insurance purposes, courts will not simply rely on registration and title documents alone. Evidence of actual financial responsibility, payment for maintenance, and insurance arrangements can create factual disputes that must be resolved at trial, even when official documents point to different ownership.
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