Courts Reinforce Limits On ATV Coverage Under Motor Vehicle Insurance Laws

It is a common principle in automobile insurance that the policy cannot limit or restrict coverage more than the state's statutory framework allows. Accordingly, consideration and application of a state's statutory motor vehicle insurance laws are relevant when adjusting claims and drafting policies regarding all-terrain vehicles (ATVs).

In 2025, Arizona's highest court joined the majority of states that hold that ATVs operated off-road do not fall under the statutory definition of underinsured motorist. Similarly, the Supreme Court of Mississippi strengthened its prior precedent that an ATV was not an uninsured motor vehicle under the statutory definition. Summaries and key takeaways from both court decisions are provided below.