The Connecticut Supreme Court determined that the insured's homeowner's policy did not cover liability for injury to her house guests caused by a car left running overnight in the attached garage. See New London County Mut. Ins. Co. v. Nantes, 2012 Conn. LEXIS 62 (Conn. Feb. 21, 2012).

   The insured had two house guests. One night she parked the car in the garage and closed the garage door, but neglected to turn of the engine. The car engine continued to run overnight, and the house filled with carbon monoxide. The house guests suffered serious neurological injuries from carbon monoxide poisoning. They suffered additional injuries when the insured dragged them, unconscious, out of the house.

   The insured submitted claims for the house guests' medical expenses to the insurer, but the claims were denied. The insurer relied upon the following exclusion in the homeowner's policy: "[c]overage for personal liability and medical payments to others does not apply to 'bodily injury' or 'property damage' arising out the ownership, maintenance, use, loading or unloading of motor vehicles . . . ."

   The insurer moved for a declaratory judgment on the policy's interpretation. The trial court granted summary judgment to the insurer. It concluded that all of the house guests' injuries, including the bodily injuries sustained while being dragged from the house, arose out of the use of the motor vehicle and were therefore excluded from coverage.

   The Conneticut Supreme Court affirmed. First, the court rejected the argument that leaving a car in one's garage did not constitute the use of a motor vehicle. The insured parked the car in the garage. Parking was plainly an employment of a car for some purpose of the user.

   The insured also argued that the doctrine of concurrent causes brought the injuries within the scope of coverage. Under the doctrine of concurrent causes, coverage was extended to a loss caused by the insured risk even though an excluded risk was a contributory cause. Here, whether the closing of the garage door, an arguably covered event, was a contributing cause of the house guests' injuries, was irrelevant. The fact that the insured's use of her motor vehicle was connected to a condition that caused injury to the house guests was enough to bring them within the motor vehicle exclusion.

   Finally, the court held that the bodily injuries, caused by being dragged out of the house, were also excluded. Because the insured's negligent act of leaving her car running in the garage was the proximate cause of the injuries sustained by being dragged from the house, it followed that those injuries arose out of the use of her car. Consequently, they were connected to use of the vehicle and excluded from coverage.