What Is A “Motor Vehicle” In An Insurance Policy

Duncanville insurance lawyers will find that the definitions in insurance policies often have their own meaning. So, what is the definition of “motor vehicle” as it relates to an insurance policy? A 1977, Texas Supreme Court opinion helps. It is styled, Slaughter v. Abilene State School et al.
Slaughter, while an employee of the Abilene State School, was injured when another employee backed a tractor over Slaughter and pinned him between the tractor wheel, the ground and a building.
The trial Court entered judgment for Slaughter and the appeals court reversed.
Abilene State School complains of the court of civil appeals holding that the 1953 John Deere tractor in question was a motor vehicle under the terms of section 19A of the Texas Tort Claims Act. Section 19A provides:
The provisions of this Act shall not apply to school districts or to junior college districts except as to motor vehicles.
It is uncontradicted that Abilene State School is an Independent School District. Since the statute does not define the phrase “motor vehicles,” it must be construed according to its ordinary import or as the phrase is generally defined. Often the phrase is defined with reference to a statute or insurance policy. It is noted that the definition appearing in the statutes regulating the registration of motor vehicles used on the public highways and providing for driver’s licenses is substantially the same as the definition generally given.
Art. 6675a-1. Definitions of terms The following words and terms, as used herein, have the meaning respectively ascribed to them in this Section, as follows:
(a) “Vehicle” means every device in, or by which any person or property is or may be transported or drawn upon a public highway, except devices moved only by human power or used exclusively upon stationary rails or tracks.
(b) “Motor Vehicle” means every vehicle, as herein defined, that is self-propelled.
(e) “Farm-tractor” means every motor vehicle designed and used primarily as a farm implement for drawing other implements of husbandry.
The definition given in Corpus Juris Secundum is “the term ‘motor vehicle’ ordinarily means a vehicle which is self-propelled, a vehicle operated by a power developed within itself and used for the purpose of carrying passengers or materials, and generally includes all vehicles propelled by any power other than muscular power, except traction engines and such motor vehicles as run only upon rails or tracks.”
The courts have held the term “motor vehicle” to be different from and broader than the term “automobile.” Common usage has made the phrase “motor vehicle” a generic term for all classes of self-propelled vehicles not operating on stationary rails or tracks, and therefore, as a result all automobiles are motor vehicles, but the contrary proposition is not true. The term “motor vehicle” is much broader than the word “automobile” and includes various vehicles which cannot be classified as automobiles. It has been held that a farm tractor is within the scope of the statute providing that no person shall operate a motor vehicle when he is in an intoxicated condition.
This Court concluded that the court of civil appeals correctly held that the tractor involved in this accident is a motor vehicle within the meaning of section 19A of the Texas Tort Claims Act.