Driver of uninsured vehicle cannot sue Insurance company for listing her as owner
Allen was apparently denied PIP benefits when she was injured in a motor vehicle collision while operating a vehicle that was uninsured. She sued American General Financial Services, arguing that the company's negligence in incorrectly placing her name on the title of the vehicle caused her to be wrongfully denied PIP benefits. She claimed that by voluntarily agreeing to prepare financial documents of title, the defendant assumed a duty to prepare the documents correctly. She claimed that her name should not have appeared on the title, meaning that she would remain eligible for PIP benefits if the vehicle was not properly insured. The Court held that the statutues governing motor vehicle titles did not apply to create a duty on the part of the defendant to accurately register ownership of the vehicle. Since Allen had no direct dealings with the defendant, she could not claim that it owed any duty to her, and therefore any errors in titling the vehicle could not form the basis of a negligence action by Allen.