A Horse-Drawn Buggy Is Not A “Motor Vehicle”For Uninsured Motorist Purposes  

Well you certainly don’t see this issue everyday: Vanessa Harper was operating a motor vehicle in Kent County, Delaware, when a horse-drawn buggy failed to stop at a stop sign and Ms. Harper’s vehicle collided with the horse.  Ms. Harper was seriously injured.  The buggy was not covered by insurance and Ms. Harper made an uninsured motorist claim.  To succeed, the horse-drawn buggy needed to qualify as a “motor vehicle.”

Addressing a question of first impression under Delaware law, which seems unsurprising, the trial court in Harper v. State Farm Mut. Auto. Ins. Co., No. K22C-07-005 NEP (Del. Super. Ct. Dec. 8, 2022) held that the plain meaning of “motor vehicle” does not include a vehicle pulled by a horse rather than powered by a motor.  Looking at a host of dictionary definitions of “motor vehicle,” the court stated: “While these definitions vary in the details, they all require self-propulsion, usually by way of an internal-combustion engine.  A horse-drawn buggy is certainly a vehicle, but it is neither self-propelled nor driven by a combustion engine. Rather, it is propelled by the movement of a horse, which (unlike a combustion engine) is not a mechanical component of the vehicle.”