Stearns County District Court File No. C0-01-4200.
Considered and decided by Willis , Presiding Judge, Hudson , Judge, and Crippen , Judge.
1. When examining whether an injury arises out of the use of a motor vehicle, the no-fault act's disregard of driver fault precludes the courts from treating prior drinking as an act of independent significance that breaks causation between vehicle use and an injury.
2. The natural and reasonable consequences of using a motor vehicle necessarily extend to the driver's efforts to respond to weather-related emergency circumstances.
The opinion of the court was delivered by: Crippen, Judge
Willis, Judge, concurring specially
Appealing the district court's final judgment in this insurance dispute, State Farm Mutual Automobile Insurance Company disputes the court's conclusion that respondent's voluntary intoxication was not an event of independent significance, that is, conduct that broke the causative tie between injuries she sustained and her use of a motor vehicle. Appellant also claims that injuries respondent sustained after leaving the vehicle, which was stuck in snow, did not arise out of the use or maintenance of the vehicle. Because we are required to apply no-fault law without consideration of fault, and because of inescapable characteristics of winter use of vehicles, we affirm.
While respondent Sheryl Dougherty was driving home in the early morning hours of December 17, 2000, after a night of drinking at a bar, her car became stuck in a snowdrift that had formed in the street. She got out of her car, locking her gloves and keys inside. Although the temperature that morning was extremely cold, respondent decided to walk to her townhouse, which was less than a block away.
Respondent attempted to walk up the parking lot entrance at her complex but discovered it was blocked by snow. Using her elbows and hands, she pulled herself through the snow. Respondent fell to the ground in the icy parking lot and could not regain her footing. She then crawled behind a garage where she lay down to rest and may have fallen asleep. By the time respondent crawled to her townhouse, 30-40 minutes had elapsed since the time she left her vehicle.
Blood tests taken at the hospital where respondent was taken showed that her blood alcohol concentration was.136. Her hands were ...