Background
Ralston Barnes sued Justin D. Beck and Farmers Group Property and Casualty Insurance Company in Louisiana’s 21st Judicial District Court. The dispute concerned whether Farmers’ uninsured motorist coverage applied to an accident involving an electric-assisted bicycle.
Farmers sought summary judgment, relying on policy language limiting uninsured motorist coverage to damages an insured is legally entitled to recover from the owner of an uninsured motor vehicle. After the district court denied summary judgment on February 6, 2026, Farmers applied to the First Circuit for supervisory review.
The Court’s Holding
The First Circuit denied Farmers’ supervisory writ application. The court provided no majority analysis, so the writ denial left the district court’s summary-judgment ruling undisturbed without an appellate merits determination that coverage exists.
Judge Hester dissented. She would have reversed and granted summary judgment to Farmers because Louisiana Revised Statute 32:1(50) excludes electric-assisted bicycles from the definition of “motor vehicle.” In her view, the policy’s conformity-to-state-law provision incorporated that statutory definition, making the policy’s uninsured motorist coverage inapplicable.
Key Takeaways
- The First Circuit denied supervisory review rather than issuing a reasoned majority ruling on the coverage question.
- The district court’s denial of Farmers’ summary-judgment motion therefore remained in place.
- The dissent concluded that an electric-assisted bicycle cannot qualify as an uninsured motor vehicle under the policy when the conformity provision is read with Louisiana law.
Why It Matters
The ruling permits Barnes’ claim against Farmers to continue at this stage, but it does not establish that the policy ultimately provides uninsured motorist coverage. Practitioners should distinguish the procedural effect of the writ denial from a precedential appellate holding on the merits.
Judge Hester’s dissent nevertheless identifies a potentially important coverage argument: a policy’s conformity clause may require an undefined term such as “motor vehicle” to be construed consistently with Louisiana’s statutory definition.