Alcazar v. Hayes Case Brief Summary | Law Case Explained

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Alcazar v. Hayes, 982 S.W.2d 845 (1998)
Most car insurance policies require a policyholder to provide notice of a claim soon after the claim arises. If the policyholder fails to meet this condition, is the insurer still obligated to provide coverage? This was the question in Alcazar versus Hayes.
Christopher Hayes and 18-year-old David Alcazar were working in a chicken house on the farm where Alcazar lived with his mother. Alcazar needed to pick up his truck, so he asked Hayes for a ride. Hayes agreed, but because Alcazar was so dirty, Hayes insisted he ride on the car’s trunk. During the drive, Alcazar was thrown off the car and hit his head on the pavement. Alcazar spent a few days in the hospital and then returned home. Only later did it become apparent that he’d suffered a permanent brain injury. At the time of the accident, Alcazar was covered by his mother’s GEICO auto insurance policy. The policy’s uninsured-motorist provision required the policyholder to notify GEICO as soon as possible after an accident. Alcazar’s mother didn’t realize he was covered, nor did she initially realize how severe Alcazar’s injuries were. As a result, she didn’t immediately notify GEICO.
One year later, Alcazar filed a state-court negligence lawsuit against Hayes, notified GEICO of the accident, and added GEICO as a defendant. GEICO moved for summary judgment, arguing that Alcazar had forfeited his uninsured-motorist coverage because he breached the policy’s notice provision. Alcazar argued that his delayed notice shouldn’t be grounds for forfeiture because it hadn’t prejudiced the company. The trial court granted summary judgment for GEICO, and the court of appeals affirmed. Alcazar appealed to the Tennessee Supreme Court.
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