## Facts

- Maryland Indemnity Insurance Company issued an automobile liability policy to Evelyn Watkins covering her 1968 Dodge Coronet; the policy was in force on December 12, 1975.
- Charlie McNeill’s car would not start, so he asked Watkins to bring her car to help jump-start his vehicle.
- Watkins authorized Edward Hill to drive her insured car to McNeill’s location.
- McNeill connected jumper cables between the two vehicles while the insured car’s engine was running; he directed the jump-start procedure.
- McNeill removed one or more caps from his own battery.
- Hill, standing outside both vehicles as an observer, lit a match; gases from McNeill’s battery ignited and the battery exploded, seriously injuring McNeill.
- The parties stipulated negligence and no contributory negligence; liability fault issues were not disputed.
- It was unclear whether the jumper cables remained attached continuously up to the explosion; the appellate court analyzed both possibilities.

## Issues

1. Whether injuries from the explosion of the claimant’s own car battery during a jump-start operation “arose out of the ownership, maintenance, or use” of the insured automobile under the liability policy.

## Decision

- The appellate court affirmed a declaratory judgment for the Maryland Insurance Guaranty Association.
- McNeill’s injuries did not “arise out of the use” of Watkins’s insured automobile within the policy’s liability coverage.
- Coverage was denied whether the jumper cables were still attached at the time of the explosion or had been disconnected earlier.

## Legal Principles

- “Arising out of the use” requires a meaningful causal connection between the insured vehicle’s use and the injury; mere “but for” involvement is insufficient, though strict tort proximate cause is not required.
- Policy language may be construed liberally to favor coverage for accident victims when genuinely ambiguous, but courts will not adopt strained or unreasonable interpretations.
- Auto liability coverage focuses on risks foreseeably identifiable with the automobile’s use as an automobile; using a vehicle only as an incidental power source, when the immediate instrumentality of harm is elsewhere, does not satisfy the required nexus.
- An insured vehicle’s tangential participation cannot convert an automobile policy into general liability coverage.

## Conclusion

Because the insured car’s role in the jump-start was ancillary and the injury resulted from conditions and conduct centered on McNeill’s own battery and the ignition source, the causal link to “use” of the insured automobile was too attenuated to trigger liability coverage.


McNeill v. Md. Ins. Guar. Ass'n, 427 A.2d 1056 (Md. Ct. Spec. App. 1981)