The Supreme Court of Virginia has been asked to determine if an all-terrain vehicle (ATV) is covered under a homeowner's insurance policy as a "farm-type vehicle," and interpreted the policy as written. The case is Erie Ins. Exch. v. Jones, 2022 Va. LEXIS 21.

In December 2019, Diamond Jones was a passenger on the back of an ATV driven by the daughter of Jennifer and Richard Rekowski. While riding the ATV, a tree branch struck and injured Jones. The incident did not occur on the Rekowski property.

Erie Insurance Exchange (Erie) provided homeowner's insurance coverage for the Rekowskis. Jones sued the Rekowskis and their daughter for her injuries. Erie answered, contending that the policy did not cover the accident. Jones then filed this action for declaratory relief against Erie, the Rekowskis and their daughter, jointly and severally, seeking judgment that Erie was responsible for claim payment. The Rekowskis failed to file an answer and a guardian ad litem for the Rekowskis' daughter filed an answer and endorsed the final order.