The New Jersey Supreme Court recently ruled that Nicky Travieso's uninsured motorist (UM) coverage is limited to $15,000, rather than the $1 million liability limit of his employer's insurance policy. This decision affects employees who are injured in accidents involving uninsured drivers while using their employer's vehicles.
The case, Nicky Travieso v. Ciara Crespo (A-10-25), was decided on August 6, 2026, and it clarifies how uninsured motorist coverage applies under New Jersey law. This ruling is particularly significant for workers who rely on their employer's insurance when driving company vehicles.
The dispute arose when Travieso was injured in an accident caused by an uninsured motorist while driving a vehicle owned by his employer, Foulke Management Corporation. The vehicle was insured under a policy issued by Zurich American Insurance Company, which provided liability coverage up to $1 million but limited UM coverage to the state-mandated minimum of $15,000. Travieso argued that he should be entitled to the higher coverage limit based on the policy's liability coverage.
In court, Travieso claimed that the New Jersey statute N.J.S.A. 17:28-1.1(f) required that employees receive the same level of uninsured motorist coverage as the named insured, which in this case was Foulke. The trial court initially sided with Travieso, ordering the policy to be reformed to provide $1 million in UM coverage. However, Zurich contested this ruling, leading to the appeal.
The Supreme Court, led by Justice Patterson, ultimately reversed the trial court's decision. The court ruled that the statute does not require that UM coverage match the policy's general liability limits. Instead, it stated, "the maximum UM coverage 'available under the policy' that must be provided to Travieso is coverage up to the UM coverage limit that his employer selected under its policy for the named insured, not up to the general third-party liability limit." This means Travieso is only entitled to the $15,000 limit.
The court's opinion emphasized that the New Jersey Legislature treated UM and underinsured motorist (UIM) coverage similarly when enacting the statute. Justice Patterson noted that the law was intended to prevent policies from providing employees with less coverage than the named insured, but it does not mandate that the coverage be equal to the liability limits.
This ruling has significant implications for employees who may find themselves in similar situations. It clarifies that the amount of UM coverage available to employees is limited to what their employer has chosen in the insurance policy, which may not always be sufficient to cover serious injuries resulting from accidents with uninsured drivers.
The decision also reinforces the importance of understanding the details of insurance policies and the limits of coverage that employers select. Employees may need to advocate for higher coverage limits to ensure adequate protection in the event of an accident.
Looking ahead, it is unclear whether Travieso or Zurich will appeal the ruling further, but the decision sets a precedent for how uninsured motorist coverage will be interpreted in New Jersey. The court's ruling could influence future cases involving insurance disputes between employees and their employers' insurance providers.
In summary, the New Jersey Supreme Court's ruling in this case underscores the complexities of insurance coverage and the importance of statutory interpretation in determining the rights of employees injured while driving their employer's vehicles. The outcome limits Travieso's recovery to $15,000, highlighting the potential gaps in coverage that employees may face.