Rhode Island Supreme Court Insurance Ruling on Personal Vehicle Coverage

The Rhode Island Supreme Court has clarified a pivotal insurance interpretation, ruling that state employees driving personal vehicles for work purposes are not covered under their employer’s commercial auto policy. This decision sided with Travelers Property Casualty Company of America in the case of Cynthia A. Roberge v. Travelers Property Casualty Company of America, finalized on May 26, 2026. The ruling followed inquiries from the First Circuit regarding insurance coverage parameters.

In this case, Cynthia Roberge, a Rhode Island state employee, experienced a traffic accident on October 18, 2018, while using her own automobile due to the unavailability of a state vehicle. She sought to claim underinsured motorist (UM/UIM) coverage from the state’s commercial auto policy, which included $1,000,000 liability per incident but minimal UM/UIM coverage limits. Travelers denied this claim, specifying that the policy's UM/UIM protections extended solely to "covered autos," excluding Roberge’s personal car.

Roberge pursued legal action in 2021, launching a lawsuit in the Providence County Superior Court claiming breach of contract and bad faith. The case was moved to federal court, where summary judgment was rendered in favor of Travelers. The matter was later referred to the Rhode Island Supreme Court to address two key statutory interpretation issues.

The first issue investigated whether the ruling in Martinelli v. Travelers Ins. Cos., which considered treating business figures as named insureds, was relevant to Roberge’s case. The court determined it was not, emphasizing Roberge's position as part of a large government workforce, unlike the closely held business scenario in Martinelli.

The second inquiry questioned whether denying UM/UIM coverage, while providing liability coverage, conflicted with state law or public policy. The court concluded that this did not violate any requirements, noting that Rhode Island law mandates UM/UIM coverage only if the vehicle is primarily insured under the policy. Roberge’s personal vehicle, covered by USAA Casualty Insurance Company, carried a $100,000 UM/UIM limit, thereby not qualifying under the state policy.

This ruling underscores the principle that insurance policies have the prerogative to define coverage specifics, consistent with policy terms. The decision strengthens the precedent that "Owned 'Autos' Only" UM/UIM designations apply, particularly for employees operating within their employment scope. The Martinelli exception continues to be applicable exclusively to privately held businesses, not extensive operations such as state government vehicle fleets.