A recent decision by the Court of Appeals of Georgia has confirmed that auto insurers can deny coverage when a vehicle is used without permission, reinforcing the strength of policy exclusions related to unauthorized use. The ruling came down on September 10, 2025, in the case of Dollar v. Georgia Farm Bureau Mutual Insurance Company, bringing clarity to how such disputes are handled in the insurance world.
The case started with a tragic accident on November 21, 2020. Queen Dollar’s son was a passenger in a truck owned by David Holder and driven by Sammy Walker. After the crash, Dollar filed a wrongful death lawsuit against both the driver, Walker, and the truck owner, Holder. A key point was Holder’s alleged negligence in letting Walker drive.
Georgia Farm Bureau, Holder’s insurer, responded by asking the court to declare that it had no duty to cover Walker under Holder’s policy. The heart of the matter was an exclusion clause in the insurance policy. It said the insurer wouldn’t cover anyone using the vehicle unless they had a reasonable belief they were allowed to do so.
Here’s what happened: Holder had given permission to his employee, Laterran Green, to use the truck for work tied to rental properties. But Holder made it clear to Green that Walker wasn’t allowed behind the wheel. Green confirmed he never gave Walker permission. On the day of the accident, Green left the truck parked at a trailer park, keys inside. Walker, who was reportedly intoxicated, took the truck without permission. Holder immediately reported it stolen, and Walker faced criminal theft charges.
When Georgia Farm Bureau argued that this exclusion applied, the trial court sided with the insurer and granted summary judgment against Dollar’s claim.
Dollar took the case to the appellate court, arguing there was some question about whether Walker had Holder’s permission and claiming that the policy exclusion was against Georgia’s public policy. The court disagreed. Judges found no evidence that Walker was ever allowed to drive, nor that he could have reasonably thought he was entitled to use the truck. They pointed out that Holder and Green both denied permission and Holder had promptly reported the vehicle stolen.
On the public policy question, the court stated that Georgia law lets insurers set clear policy terms and enforce exclusions as long as they don’t break the law. Past cases have supported such exclusions for unauthorized users, meaning this decision fits within established legal views.
For insurance companies, this ruling highlights the importance of explicit policy language and confirms that exclusions for unauthorized use are valid and enforceable. It also underscores how crucial permission is when it comes to liability coverage. This case shows that when users don’t have permission — or a reasonable belief of permission — insurers can refuse coverage. That makes a big difference in how claims like this are handled and how risks are managed.