The central issue in this case was whether a camper trailer owned by a homeowners policy insured was covered as unscheduled personal property to which a substantial amount of insurance was applicable, or whether it was properly a "trailer" for which a special limit was provided. "Trailers not used with watercraft" were subject to a special limit of $1,000.

The vehicle in question had two axles and four tires located behind its center, hard non-collapsible sides, a trailer hitch in the front and weighed 3,320 pounds empty. The vehicle was destroyed by windstorm while parked in the yard of the covered dwelling. The insurer confined payment of the insured's claim to $1,000, contending that the property was a "trailer not used with watercraft" and subject to the special limit for such an item. In the course of litigation that followed, the trial court determined that the object in question was not a "trailer" within the special limit provision, and entered judgment for the insured for $6,560, the actual value of the camper trailer. The insurer appealed.

The insurer argued that the vehicle was a "trailer" within the meaning of the limitation clause. The Virginia Supreme Court, referring to paragraph 46.2-100 of the pertinent Virginia statute dealing with motor vehicles, found "trailer" defined as "every vehicle without motive power designed for carrying property or passengers wholly on its own structure and for being drawn by a motor vehicle, including mobile homes."

The court concluded that this definition of "trailer" and others to which reference was made, including accepted definitions in popular dictionaries, applied to the insured's vehicle. The special limits limitation in the policy was found applicable to the insured's claim. The judgment of the trial court was reversed in favor of the insurance company and against the insured.

(UNITED STATES FIDELITY & GUARANTY COMPANY, Appellant v. McGLOTHIN, Appellee. Virginia Supreme Court. Record No. 891176. June 8, 1990. CCH 1990 Fire and Casualty Cases, Paragraph 2580.)