Prudential Insurance of America v. Superior Court

I. Introduction

In this insurance coverage action, defendants Prudential Insurance Company of America and Prudential Health Care Plan of California, Inc. petition for extraordinary relief from the order of respondent court denying their motion for summary judgment. To determine whether extraordinary relief is warranted, we consider an issue of first impression in California insurance law concerning the interpretation of the phrase “enrolled as a full-time student in a school” in a group health policy that provides medical coverage to employees’ dependents aged 19 to 24 who meet that description. The courts of other jurisdictions have determined that the plain meaning of the word “enrolled” is that the dependent is registered at an academic institution, and that the phrase “full-time student” plainly means that the dependent spends a substantial amount of time attending classes. We find these decisions persuasive. Therefore, because it is undisputed that at the time of her catastrophic accident in November 1994 plaintiff Michelle L. Dunniway was not registered at an academic institution and was not attending any classes, as a matter of law she did not qualify for…