Maryland Insurance Administration v. State Farm Mutual Automobile Insurance Co.

Watts, J. This case requires the Court to determine whether an insured may receive personal injury protection (“PIP”) coverage, under a personal motor vehicle liability insurance policy held by the insured, for injuries sustained while driving a taxicab owned by the insured but not covered by the personal motor vehicle liability insurance policy, where the personal motor vehicle liability insurance policy contains an exclusion for motor vehicles owned but not insured under the policy. Under Maryland law, generally, insurers are required to ³²⁸ provide drivers with liability, PIP, and uninsured/underin-sured motorist (“UM/UIM”) coverage. See Md. Code Ann., Ins. (1997, 2011 Repl.

Vol., 2016 Supp.) (“IN”) §§ 19-504,19-505, 19-509; Md. Code Ann., Transp. (1977, 2012 Repl. Vol., 2016 Supp.) (“TR”) § 17-103. And, where a motor vehicle insurance policy contains PIP coverage and UM/UIM coverage, an insurer is required to provide PIP coverage to an insured or an insured’s resident family member who is injured in a motor vehicle accident “while occupying a motor vehicle for which the coverages described in [IN] §§ 19-505 [ (PIP coverage) ] and 19-509 [ (UM/UIM coverage) ] are not in effect[.]” IN § 19-513(d)(l)(i).

The definition of a “motor vehicle” set forth in IN § 19—501(b)(2)(ii), however, expressly excludes taxicabs as “motor vehicles” for purposes of Subtitle 5 of Title 19 of the Insurance Article; thus, IN § 19-505(a) does not require insurers to offer PIP coverage in policies insuring taxicabs. This case raises the overall issue of whether an insurer of a personal motor vehicle liability insurance policy, which includes PIP coverage, is responsible for PIP coverage for injuries that an insured sustained while driving a taxicab owned by the insured but not covered by the personal motor vehicle liability insurance policy, or whether the personal motor vehicle liability insurance policy’s owned but not insured exclusion applies, such that the insurer is not responsible for PIP coverage under those circumstances. To answer that overarching question, this Court must determine three very specific issues: (1) whether a taxicab is a “motor vehicle” for purposes of the statutory exclusion from PIP coverage under IN § 19-505(c)(l)(ii) and for the payment of benefits under IN § 19—513(d)(l)(i); (2) whether “uninsured motor vehicle” for purposes of IN § 19—505(c)(l)(ii) means uninsured altogether, uninsured for PIP coverage, or not insured under the relevant motor vehicle liability insurance policy; and (3) whether the exclusion in the personal motor vehicle liability insurance policy in this case—which excluded coverage, in pertinent part, for the insured “while occupying a motor vehicle owned by [the insured] ... and which is not insured under the ³²⁹ liability coverage of this policy” (capitalization omitted)—is authorized by the statutory exclusion from PIP coverage set forth in IN § 19-505(c)(l)(ii), the “owned but uninsured” exclusion. As to the primary question presented in this case, we hold that an insurer of a personal motor vehicle liability insurance policy, which includes PIP coverage, is not responsible, as a result of the application of the personal motor vehicle liability insurance policy’s owned but not insured exclusion, for PIP coverage for injuries the insured sustained while driving a taxicab owned by the insured but not covered by the personal motor vehicle liability insurance policy.

As to the more specific underlying issues, we conclude that: (1) a taxicab is a “motor vehicle” for purposes of the owned but uninsured exclusion from PIP coverage set forth in IN § 19-505(c)(l)(ii) and for the payment of benefits under IN § 19-513(d)(l)(i); (2) “uninsured motor vehicle” under IN § 19—505(c)(l)(ii) means uninsured for PIP coverage, such that a motor vehicle, including a taxicab, that is not insured for PIP coverage is an “uninsured motor vehicle” for purposes of IN § 19-505(c)(l)(ii); and (3) the exclusion in the personal motor vehicle insurance policy in this case is authorized by the owned but uninsured exclusion from PIP coverage set forth in IN § 19-505(c)(l)(ii). Accordingly, we affirm the judgment of the Court of Special Appeals. BACKGROUND On November 14, 2011, Alhassan Bundu-Conteh (“Bundu-Conteh”), Respondent, was rear-ended by a motor vehicle while driving his taxicab. Bundu-Conteh sustained personal injuries.

At the time of the accident, Bundu-Conteh owned two vehicles: a 1997 Jeep Grand Cherokee (“the Jeep”) and a 2006 Ford Crown Victoria taxicab (“the taxicab”). The Jeep was insured under a liability and no-fault policy with State Farm Mutual Automobile Insurance Company (“State Farm”), Respondent, which included PIP coverage. The taxicab was insured by Amalgamated Insurance Company (“Amalgamat ³³⁰ ed”) and earned liability-only coverage, which does not include PIP coverage. 1 Following the accident, Bundu-Conteh submitted a PIP claim to State Farm for the injuries that he sustained. State Farm denied Bundu-Conteh’s PIP claim, relying on the following exclusion (“the third exclusion”) for no-fault coverage: Exclusions THERE IS NO COVERAGE: # * # 3.

FOR YOU OR ANY RESIDENT RELATIVE WHILE OCCUPYING A MOTOR VEHICLE OWNED BY YOU OR ANY RESIDENT RELATIVE AND WHICH IS NOT INSURED UNDER THE LIABILITY COVERAGE OF THIS POLICY!.] Bundu-Conteh subsequently filed a complaint with the Maryland Insurance Administration (“the MIA”), Petitioner. In the complaint, Bundu-Conteh contended that the third exclusion was inapplicable to him because, at the time of the accident, he was driving a taxicab, which IN § 19-501(b)(2)(ii) excludes from the definition of “motor vehicle.” 2 Alternatively, Bundu-Conteh argued that, even if the taxicab were categorized as a “motor vehicle,” the third exclusion in the State Farm policy is incompatible with well-settled Maryland law. ³³¹ On December 27, 2012, after completing its review of the ease, the MIA concluded that State Farm’s denial of Bundu-Conteh’s PIP claim violated IN §§ 4-118, 3 19-505, 4 19-513, 5 and 27-303. 6 Specifically, the MIA determined that, pursuant to IN § 19—513(d), State Farm is obligated to provide PIP benefits to its insured policy holders who are injured in a motor vehicle accident, subject to limited exclusions. Accord ³³² ing to the MIA, the third exclusion in State Farm’s policy is incompatible 'with the exclusions under IN § 19-505(c) and thus constitutes “an arbitrary and capricious denial of a claim without just cause[.]” On January 25, 2013, State Farm appealed the MIA’s determination and requested a hearing. Specifically, State Farm contended that the third exclusion fell squarely within the “owned but uninsured” exclusion under IN § 19-505(c)(l)(ii) and, thus, was permissible.

According to State Farm, the taxicab was “uninsured” for the purposes of IN § 19—505(c)(l)(ii) because it was not insured under the State Farm policy. Both State Farm and the MIA, on Bundu-Conteh’s behalf, filed with the Maryland Insurance Commissioner (“the Commissioner”) cross-motions for summary decision. On August 15, 2013, the Commissioner held a hearing on the cross-motions for summary decision. On January 24, 2014, the Commissioner issued a Memorandum and Final Order, concluding that State Farm’s denial of coverage to Bundu-Conteh violated IN §§ 19-505 and 19-513.

The Commissioner determined that the third exclusion is not a permissible exclusion under IN § 19-505(c). Specifically, the Commissioner determined that, under the plain language of IN § 19-505(e)(l)(ii), the meaning of “uninsured motor vehicle” is “a motor vehicle without insurance.” Thus, the Commissioner concluded that to interpret IN § 19—505(c)(l)(ii) as excluding coverage for individuals like Bundu-Conteh, who carried PIP coverage on their vehicles and were not injured while in an “uninsured” vehicle, “would be contrary to the remedial legislative purpose of assuring compensation for damages to victims of motor vehicle accidents without regard to fault.” The Commissioner, therefore, granted the MIA’s motion for summary decision and ordered State Farm to pay Bundu-Conteh’s PIP claim arising from the accident plus 1.5% interest for each intervening month starting 30 days after Bundu-Conteh first submitted his PIP claim. On February 20, 2014, State Farm filed in the Circuit Court for Baltimore City (“the circuit court”) a petition for judicial review. On January 9, 2015, the circuit court issued a Memo ³³³ randum and Order reversing the Commissioner’s Final Order.

On January 29, 2015, the MIA noted an appeal to the Court of Special Appeals. In an unreported opinion dated March 15, 2016, the Court of Special Appeals affirmed the judgment of the circuit court. State Farm subsequently requested that the Court of Special Appeals report the opinion. On June 1, 2016, the Court of Special Appeals reported the opinion.

See Md. Ins. Admin. v. State Farm Mut. Auto, Ins. Co., 228 Md.App. 126 , 137 A.3d 310 (2016).

The MIA thereafter filed in this Court a petition for a writ of certiorari, which we granted on September 2, 2016. See Md. Ins. Admin. v. State Farm Mut. Auto.

Ins., 450 Md. 102 , 146 A.3d 463 (2016). DISCUSSION The Parties’ Contentions The MIA contends that the Court of Special Appeals erred by not affording deference to the Commissioner’s interpretation of IN § 19-505. According to the MIA, the Commissioner correctly determined that, at the time of the accident, Bundu-Conteh was not driving an “uninsured motor vehicle” and, thus, the exclusion under IN § 19—505(c)(1)(ii) does not apply. Indeed, the MIA argues that the taxicab was neither a “motor vehicle” nor “uninsured.” Furthermore, the MIA asserts that the third exclusion of State Farm’s policy is not authorized by IN § 19-505(c), and thus is invalid.

State Farm responds that the Commissioner’s interpretation of “uninsured” for purposes of IN § 19-505 was erroneous. Specifically, State Farm argues that well-established Maryland law requires that the definition of “uninsured motor vehicle” be interpreted contextually, and, in this context, “uninsured motor vehicle” refers to vehicles without PIP coverage. Thus, State Farm asserts that Bundu-Conteh’s taxicab was, by definition, an uninsured motor vehicle at the time of the accident. State Farm further contends that the Commissioner’s interpretation of the taxicab as “insured” for the purposes of IN § 19-505 provides a windfall for individuals like Bundu-Con- ³³⁴ teh, who, theoretically, could carry PIP coverage on only one vehicle, purchase multiple other vehicles, insure them at the bare minimum level of coverage, and subsequently rely on the single PIP policy to cover all of the vehicles.

State Farm also argues that the Commissioner misapplied relevant Maryland case law. Specifically, State Farm argues that the Commissioner erroneously relied on Nasseri v. GEICO Gen. Ins. Co., 390 Md. 188 , 888 A.2d 284 (2005), which, according to State Farm, is distinguishable from the instant case, as it did not contemplate the owned but uninsured exclusion under IN § 19—505(c)(l)(ii).

In reply, the MIA contends that the Commissioner’s plain language interpretation of “uninsured motor vehicle” is consistent with the underlying legislative intent underlying the no-fault provisions of the Insurance Article. The MIA argues that the General Assembly enacted the owned but uninsured exclusion to specifically address “uninsured” vehicles—ie. vehicles entirely lacking insurance—not those lacking only PIP coverage. Additionally, the MIA asserts that the statutes in the Insurance Article are remedial, and should be liberally construed in favor of the insured. Furthermore, the MIA maintains that the Commissioner’s interpretation of IN § 19-505 would not provide insured motorists like Bundu-Conteh with a windfall, but, in the event that it did, this would be an issue for the General Assembly to resolve.

Standard of Review In Md. Aviation Admin. v. Noland, 386 Md. 556, 571 , 873 A.2d 1145, 1154 (2005), this Court stated: A court’s role in reviewing an administrative agency adjudicatory decision is narrow; it is limited to determining if there is substantial evidence in the record as a whole to support the agency’s findings and conclusions, and to determine if the administrative decision is premised upon an erroneous conclusion of law. (Citations and internal quotation marks omitted); see also Charles Cnty. Dep’t of Soc. Servs. v. Vann, 382 Md. 286, 295 , 855 A.2d 313, 319 (2004) (“When an agency makes ‘conclu ³³⁵ sions of law’ in a contested case, the [Administrative Procedure Act] permits the court, on judicial review, to decide the correctness of the agency’s conclusions and to substitute the court’s judgment for that of the agency’s.” (Citations omitted)).

Furthermore, “an administrative agency’s interpretation and application of the statute which the agency administers should ordinarily be given considerable weight by reviewing courts.” Bd. of Physician Quality Assurance v. Banks, 354 Md. 59, 69 , 729 A.2d 376, 381 (1999) (citations omitted). “However, if we determine that the agency’s decision is based on an erroneous conclusion of law, no deference is given to those conclusions.” Kenwood Gardens Condos., Inc, v. Whalen Props., LLC, 449 Md. 313, 325 , 144 A.3d 647, 655 (2016). In addition, because the issue in this case involves statutory interpretation, we set forth the pertinent rules of statutory construction: The cardinal rule of statutory construction is to ascertain and effectuate the intent of the General Assembly. As this Court has explained, to determine that purpose or policy, we look first to the language of the statute, giving it its natural and ordinary meaning. We do so on the tacit theory that the General Assembly is presumed to have meant what it said and said what it meant.

When the statutory language is clear, we need not look beyond the statutory language to determine the General Assembly’s intent. If the words of the statute, construed according to their common and everyday meaning, are clear and unambiguous and express a plain meaning, we will give effect to the statute as it is written. In addition, we neither add nor delete words to a clear and unambiguous statute to give it a meaning not reflected by the words that the General Assembly used or engage in forced or subtle interpretation in an attempt to extend or limit the statute’s meaning. If there is no ambiguity in the language, either inherently or by reference to other relevant laws or circumstances, the inquiry as to legislative intent ends.

If the language of the statute is ambiguous, however, then courts consider not only the literal or usual meaning of the ³³⁶ words, but their meaning and effect in light of the setting, the objectives, and the purpose of the enactment under consideration. We have said that there is an ambiguity within a statute when there exist two or more reasonable alternative interpretations of the statute. When a statute can be interpreted in more than one way, the job of this Court is to resolve that ambiguity in light of the legislative intent, using all the resources and tools of statutory construction at our disposal. If the true legislative intent cannot be readily determined from the statutory language alone, however, we may, and often must, resort to other recognized indicia—among other things, the structure of the statute, including its title; how the statute relates to other laws; the legislative history, including the derivation of the statute, comments and explanations regarding it by authoritative sources during the legislative process, and amendments proposed or added to it; the general purpose behind the statute; and the relative rationality and legal effect of various competing constructions.

In construing a statute, we avoid a construction of the statute that is unreasonable, illogical, or inconsistent with common sense. In addition, the meaning of the plainest language is controlled by the context in which is appears. As this Court has stated, because it is part of the context, related statutes or a statutory scheme that fairly bears on the fundamental issue of legislative purpose or goal must also be considered. Thus, not only are we required to interpret the statute as a whole, but, if appropriate, in the context of the entire statutory scheme of which it is a part.

Bottini v. Dep’t of Fin., 450 Md. 177, 187-89 , 147 A.3d 371, 378 (2016) (citation omitted). Relevant Law In 1972, the General Assembly required PIP coverage as part of a larger statutory scheme that introduced no-fault coverage to the Maryland insurance marketplace and created ³³⁷ the Maryland Automobile Insurance Fund (“the MAIF”) to expand access to motor vehicle insurance. See 1972 Md. Laws 281 -82 (Ch. 73, H.B. 444). This Court has remarked that “[t]he requirement of [PIP] coverage was a major innovation in 1972; it represented the State’s limited endorsement of the concept of no-fault automobile insurance, then being widely touted as the answer to perceived flaws in our system of compensating those injured in motor vehicle accidents.” Md. Auto.

Ins. Fund v. Perry, 356 Md. 668, 675 , 741 A.2d 1114, 1118 (1999). Broadly, “[t]he thrust of the 1972 law was to extend, not restrict, insurance protection, especially a limited amount of primary, no-fault benefits for wage loss and basic medical expenses.” Id. at 675 , 741 A.2d at 1118 . Indeed, this Court has explained: PIP is a form of no fault insurance, that allows the insured to recover for medical expenses and lost income resulting from a motor vehicle accident.

Its main purpose is to assure financial compensation to victims of motor vehicle accidents without regard to the fault of a named insured or other persons entitled to PIP benefits. TravCo Ins. Co. v. Williams, 430 Md. 396, 403 , 61 A.3d 50, 53-54 (2013) (citations and internal quotation marks omitted); see also Bishop v. State Farm Mut, Auto Ins., 360 Md. 225, 230 , 757 A.2d 783, 785 (2000) (same). Under IN § 19-505(a), insurers are required to provide PIP coverage as part of their policies: 7 (a) Coverage required.—Unless waived in accordance with § 19-506 of this subtitle or rejected in accordance with § 19-506.1 of this subtitle, each insurer that issues, sells, or delivers a motor vehicle liability insurance policy in the State shall provide coverage for the medical, hospital, and ³³⁸ disability benefits described in this section for each of the following individuals: (1) except for individuals specifically excluded under § 27-609 of this article: (i) the first named insured, and any family member of the first named insured who resides in the first named insured’s household, who is injured in any motor vehicle accident, including an accident that involves an uninsured motor vehicle or a motor vehicle the identity of which cannot be ascertained; and (ii) any other individual who is injured in a motor vehicle accident while using the insured motor vehicle with the express or implied permission of the named insured; (2) an individual who is injured in a motor vehicle accident while occupying the insured motor vehicle as a guest or passenger; and (3) an individual who is injured in a motor vehicle accident that involves the insured motor vehicle: (i) as a pedestrian; or (ii) while in, on, or alighting from a vehicle that is operated by animal or muscular power.

As to the amount of PIP coverage required, IN § 19—505(b)(2) provides that “[tjhe minimum medical, hospital, and disability benefits provided by an insurer under this section shall include up to $2,500 for” various payments. Under IN § 19-506(a), however, an insured may waive PIP coverage. 8 If an insured waives PIP coverage, the insured is prevented from making a claim for PIP under any policy. See Perry, 356 Md. at 676 , 741 A.2d at 1118 (“In allowing insureds ³³⁹ to waive PIP benefits under their own policies, however, the [General Assembly] determined that a waiver of PIP benefits was a total waiver, and that, if an insured waived such benefits under his/her own policy, the insured could not collect those benefits from any other insurer.” (Emphasis in original)). 9 Similarly, an insured may also waive higher levels of UM/UIM coverage, provided that the insured carries liability insurance in excess of the minimum coverage required under Maryland law. See IN § 19~510(a) and (b); Swartzbaugh v. Encompass Ins.

Co. of Am., 425 Md. 614, 618 , 42 A.3d 587, 589 (2012) (“Under the State insurance code, UM coverage under a motor vehicle insurance policy is by default equal to the liability coverage under the policy. This level of coverage may be waived, however, in favor of a lesser amount at least equal to the minimum coverage required by the motor vehicle law.” (Citations omitted)). IN § 19-513(d)(l) governs the payment of benefits where coverage under IN §§ 19-505 and 19-509 is not in effect, providing as follows: The insurer under a policy that contains the coverages described in §§ 19-505 and 19-509 of this subtitle shall pay the benefits described in §§ 19-505 and 19-509 to an individual insured under the policy who is injured in a motor vehicle accident: (i) while occupying a motor vehicle for which the coverages described in §§ 19-505 and 19-509 of this subtitle are not in effect; or (ii) by a motor vehicle for which the coverages described in §§ 19-505 and 19-509 of this subtitle are not in effect as a pedestrian, while in, on, or alighting from a vehicle powered by animal or muscular power, or while on or alighting from an animal. Indeed, unlike liability coverage, generally, PIP coverage follows the insured, not the motor vehicle.

See Nasseri, 390 Md. ³⁴⁰ at 196 , 888 A.2d at 288 (“The language of the Insurance Article, as well as numerous opinions by this Court, make it clear that an insured, who has PIP coverage under a policy on the insured’s motor vehicle, and who is injured in an accident while occupying a different motor vehicle owned by someone else, is ordinarily entitled to PIP coverage under the policy on the insured’s vehicle.”). One exception to the requirement of PIP coverage—aside from waiver or rejection of PIP coverage under IN §§ 19-506 and 19-506.1, respectively—involves taxicabs. IN § 19-501(b)(2)(ii), states that the term “motor vehicle” “does not include ... a taxicab as defined in § 11-165 of the Transportation Article.” A taxicab is not required to be insured under a policy that includes PIP coverage. 10 In Nasseri, 390 Md. at 195-96 , 888 A.2d at 288 , we noted that the purpose of the legislation excluding a taxicab from the definition of “motor vehicle” “was simply to provide that the compulsory automobile liability insurance policies on taxicabs and certain other vehicles did not have to contain policy provisions for PIP and some other statutory coverages.” See also id at 191, 888 A.2d at 285 (“At the time of the accident, the taxicab was covered only by liability insurance, in accordance with the minimum requirements of Maryland law applicable to taxicabs.”). Additionally, under certain circumstances, an insurer may exclude PIP coverage.

See IN § 19-505(c). Relevant to this case is the “owned but uninsured” exclusion set forth in IN § 19—505(c)(1) (ii): An insurer may exclude from the coverage described in this section benefits for: [[Image here]] ³⁴¹ (ii) the named insured or a family member of the named insured who resides in the named insured’s household for an injury that occurs while the named insured or family member is occupying an uninsured motor vehicle owned by: 1. the named insured; or 2. an immediate family member of the named insured who resides in the named insured’s household. The General Assembly created the owned but uninsured exclusion through the enactment Chapter 573 of the Acts of 1982 (“Chapter 573”). 1982 Md. Laws 3442 -43 (Vol. IV, Ch. 573, S.B. 983); see also Nasseri, 390 Md. at 200-01 , 888 A.2d at 291 .

Chapter 573 introduced the following language regarding PIP coverage: THE INSURER MAY EXCLUDE FROM THE COVERAGE PRESCRIBED IN § 539, BENEFITS FOR THE NAMED INSURED OR MEMBERS OF HIS FAMILY RESIDING IN THE HOUSEHOLD WHEN OCCUPYING AN UNINSURED MOTOR VEHICLE THAT IS OWNED BY THE NAMED INSURED OR A MEMBER OF HIS IMMEDIATE FAMILY RESIDING IN HIS HOUSEHOLD. 1982 Md. Laws 3444 (Vol. IV, Ch. 573, S.B. 983). 11 Chapter 573 provided similar language regarding exclusion of UM/UIM coverage: HOWEVER, THE INSURER MAY EXCLUDE FROM COVERAGE BENEFITS FOR THE NAMED INSURED OR MEMBERS OF HIS FAMILY RESIDING IN THE HOUSEHOLD WHEN OCCUPYING, OR STRUCK AS A PEDESTRIAN BY, AN UNINSURED MOTOR VEHICLE THAT IS OWNED BY THE NAMED INSURED OR A MEMBER OF HIS IMMEDIATE FAMILY RESIDING IN HIS HOUSEHOLD. ³⁴² 1982 Md. Laws 3443 (Vol. IV, Ch. 573, S.B. 983). 12 The General Assembly created the owned but uninsured exclusion on the heels of this Court’s decision in Pa. Nat’l Mut.

Cas. Ins. Co. v. Gartelman, 288 Md. 151 , 416 A.2d 734 (1980). In that case, the plaintiff, Doris Gartelman (“Gartelman”), was injured while driving her husband’s moped when another motor vehicle forced the moped off the road.

See id. at 153 , 416 A.2d at 735 . At the time of the accident, the moped was uninsured, but Gartelman claimed PIP and UM coverage under her husband’s insurance policy with Pennsylvania National Mutual Casualty Insurance (“Pennsylvania National”). See id. at 153 , 416 A.2d at 735 . Pennsylvania National denied Gartelman’s claim, relying on an owned but uninsured exclusion in the policy.

See id. at 155 , 416 A.2d at 736 . Given that Maryland’s motor vehicle insurance statutes did not include or authorize an owned but uninsured exclusion, this Court invalidated Pennsylvania National’s policy exclusion, explaining: [The statute] expressly provides for only four exclusions from the required PIP coverage. It does not expressly provide an exclusion for an insured occupying an uninsured motor vehicle owned by a named insured. We decline to insert such an exclusion which would be contrary to the remedial legislative purpose of assuring compensation for damages to victims of motor vehicle accidents without regard to fault.

Id. at 156-157 , 416 A.2d at 737 . Indeed, following Gartelman, we remarked that “this Court has consistently held that exclusions from statutorily mandated insurance coverage not expressly authorized by the [General Assembly] generally will not be recognized.” Nasseri, 390 Md. at 198 , 888 A.2d at 290 (citations and internal quotation marks omitted). In rendering the Final Order, the Commissioner relied on Nasseri, 390 Md. 188 , 888 A.2d 284 , so we set forth the facts and holdings of that case in detail. In Nasseri, id. at 196 , 888 ³⁴³ A.2d at 288-89 , we held that a taxicab driver was entitled to PIP coverage from the insurance policy on his personal vehicle when he sustained injuries in a motor vehicle accident while driving a taxicab that he did not own.

The plaintiff, Ebrahim Nasseri (“Nasseri”), was injured in a motor vehicle accident while driving a taxicab that belonged to Action Taxicab, Inc. See id. at 191 , 888 A.2d at 285 . The taxicab was covered under a liability-only policy, but Nasseri maintained insurance coverage, including PIP coverage, on his personal vehicle through GEICO General Insurance Company (“GEICO”). See id. at 191 , 888 A.2d at 285-86 . Nasseri filed a claim on his GEICO policy for the injuries that he sustained in the accident.

See id. at 191 , 888 A.2d at 286 . GEICO denied the claim, arguing that, because Nasseri was driving a taxicab at the time of the accident, he was not injured in a “motor vehicle accident” for purposes of IN § 19-505. Nasseri, 390 Md. at 191 , 888 A.2d at 286 . Furthermore, GEICO asserted that Nasseri’s policy did not apply because it included an exclusion that specified that an insured was “not covered if injured while in, or through being struck by, any motor vehicle which is not an insured auto if it is ... available for the regular use of the insured.” Id. at 190-92, 888 A.2d at 285-86 (ellipsis in original) (internal quotation marks omitted).

The trial court found in favor of GEICO. See id. at 192 , 888 A.2d at 286 . We reversed. See id. at 193 , 888 A.2d at 286 .

Turning first to the issue of whether Nasseri was involved in a “motor vehicle accident,” we observed the following: For purposes of this case, we shall assume arguendo that the statutory phrase “motor vehicle accident” in subsection [IN § 19—501](c)(l) incorporates the taxicab exclusion in subsection [IN § 19—501 ](b)(2)(ii), and that an accident between two taxicabs might not be a “motor vehicle accident” within the meaning of subsection [IN § 19-501](c)(l). Nevertheless, as long as another motor vehicle, which is not a taxicab or bus, is involved in the accident, such accident plainly comes within the definition of “motor vehicle accident” in subsection [IN § 19-501](c)(l). The subsection requires only the involvement of one motor vehicle for there ³⁴⁴ to be a motor vehicle aecident; it does not require that all vehicles involved in the collision be “motor vehicles.” [[Image here]] Nasseri was certainly injured in a motor vehicle accident under the language of the statute, and [IN] § 19-605 provides PIP coverage for anyone injured in any motor vehicle accident. Nasseri, 390 Md. at 193-94 , 888 A.2d at 287 (italics in original).

Interpreting the language of IN § 19-513, we explained that the circumstances of Nasseri’s accident appeared to fall squarely within the coverage contemplated under the Insurance Article: The applicability of [IN] § 19-505, under the circumstances of this case, is reinforced by the language of [IN] § 19-513(d)(1)® [ ]. [IN § ] 19—513(d)(l)(i) states: “[ ](1) The insurer under a policy that contains the coverages described in §§ 19-505 and 19-509 of this subtitle shall pay the benefits described in §§ 19-505 and 19-509 to an individual insured under the policy who is injured in a motor vehicle accident: (i) while occupying a motor vehicle for which the coverages described in §§ 19-505 and 19-509 of this subtitle are not in effect....” It would appear that the above-quoted language was directly aimed at circumstances like those presented here. The vehicles “for which the coverages described in [IN] §§ 19-505 and 19-509” would legally not be “in effect” are taxicabs, buses, vehicles owned by the State of Maryland, and vehicles for which the first named insured has made “an affirmative written waiver of PIP benefits.” In this case, Nasseri had an insurance policy providing PIP benefits, and he was occupying a motor vehicle for which PIP benefits were not in effect. A holding that he was not entitled to PIP benefits, precisely because he was occupying a vehicle for which PIP benefits were not in effect, could not be reconciled with [IN] § 19—513(d)(l)(i). ³⁴⁵ Nasseri, 390 Md. at 194-95 , 888 A.2d at 287-88 (emphasis added) (ellipsis in original) (brackets and footnotes omitted). We considered the legislative intent behind excluding taxicabs from classification as “motor vehicles” and observed that the rationale for doing so was merely to exclude taxicabs and certain other vehicles from compulsory PIP and similar coverage.

See id. at 195-96, 888 A.2d at 288 . Thus, we explained that “[t]he purpose was not to negate required PIP and other required coverages, under policies on all other types of motor vehicles, whenever a taxicab happened to be involved in an accident with another type of motor vehicle.” Id. at 196 , 888 A.2d at 288 . We, therefore, concluded that “an insured, who has PIP coverage under a policy on the insured’s motor vehicle, and who is injured in an accident while occupying a different motor vehicle owned by someone else, is ordinarily entitled to PIP coverage under the policy on the insured’s vehicle.” Id. at 196 , 888 A.2d at 288 . We also considered whether GEICO’s “regular use” exclusion was permissible under IN § 19-505.

See Nasseri, 390 Md. at 197 , 888 A.2d at 288 . 13 Looking to the plain language of IN § 19-505(c), we concluded that the “regular use” exclusion was not one of the exclusions contemplated by the General Assembly, and thus was impermissible. See Nasseri, 390 Md. at 197-98 , 888 A.2d at 289 . We observed that, under well-settled law in Maryland, this Court will not expand the exclusions to ³⁴⁶ insurance coverage beyond those explicitly enumerated by the General Assembly. See id. at 198 , 888 A.2d at 289 .

As to an owned but uninsured exclusion, in Gov’t Emps. Ins. Co. v. Comer, 419 Md. 89, 98 , 18 A.3d 830, 835 (2011), this Court upheld the exclusion of UM/UIM coverage under IN § 19—509(f)(1) when the vehicle was owned by the insured but covered under a different insurance policy. IN § 19—509(f)(1) pertains to UM/UIM benefits, and includes language that closely mirrors IN § 19—505(c)(l)(ii): (f) Exclusions.—An insurer may exclude from the uninsured motorist coverage required by this section benefits for: (1) the named insured or a family member of the named insured who resides in the named insured’s household for an injury that occurs when the named insured or family member is occupying or is struck as a pedestrian by an uninsured motor vehicle that is owned by the named insured or an immediate family member of the named insured who resides in the named insured’s household[.] In Comer, 419 Md. at 98 , 18 A.3d at 835 , we concluded that a motorcycle was “uninsured” for purposes of IN § 19-509(f)(1)» and thus was excluded from coverage.

In that case, the plaintiff, Ray Comer (“Comer”), was injured in a motor vehicle accident when his motorcycle collided with another vehicle. See id. at 91-93,18 A,3d at 831-32. The medical costs associated with Comer’s injuries exceeded $200,000. See id. at 92,18 A,3d at 831.

Comer had insured the motorcycle under a policy with Progressive Insurance Co., which included an UM/UIM limit of $50,000. See id. at 92, 18 A.3d at 831 . At the time of the accident, Comer was living with his father, who owned a 2000 Buick that was covered under a policy with GEICO with a UM/UIM limit of $300,000. See id. at 92 , 18 A.3d at 831 .

Comer filed a claim with GEICO, asserting that he qualified as “insured” because he lived with his father. See id. at 92 , 18 A.3d at 832 . GEICO denied Comer’s claim on the ground of the following policy exclusion: “EXCLUSIONS [[Image here]] ³⁴⁷ 4. Bodily Injury sustained by an insured while occupying a motor vehicle owned by an insured and not described in the declarations and not covered by the bodily injury and property damage liability coverages of this policy is not covered.” Id. at 93 , 18 A.3d at 832 (emphasis in original).

Comer filed a complaint against GEICO, and the trial court ultimately issued a declaratory judgment in Comer’s favor, finding that GEI-CO’s exclusion was ambiguous and impermissible under IN § 19—509(f)(1). See Comer, 419 Md. at 93-95 , 18 A.3d at 832-33 . We reversed. See id. at 100 , 18 A.3d at 836 .

Turning first to the issue of ambiguity, we determined that the language in GEICO’s exclusion was not ambiguous, and observed that the language of the exclusion “clearly preclude[d] coverage of Comer’s claim under the GEICO policy[ ]” because he was driving a vehicle that he owned and that was not covered under the GEICO policy, Id. at 96 , 18 A.3d at 834 . We then considered whether the exclusion was permissible under IN § 19—509(f)(1), and concluded that it was: In determining whether exclusion number 4, as applied to this case, is authorized by the statute, the only possible ambiguity is the statute’s reference to “an uninsured motor vehicle” owned by the family member. Nevertheless, Comer’s motorcycle was “uninsured” under the declarations and liability coverage of the GEICO policy. Moreover, as earlier noted ... the word “uninsured” in [IN] § 19-509 includes “underinsured.” Comer’s motorcycle was clearly an underin-sured motor vehicle.

Comer, 419 Md. at 98 , 18 A.3d at 835 . In reaching this conclusion, we observed that invalidating the owned but uninsured UM/UIM exclusion could potentially produce an illogical result: One purpose of exclusion 4 in the GEICO policy, as well as a purpose of [IN] § 19—509(f)(1), is obviously to prevent a family, owning several motor vehicles, from insuring only one or two of them with an insurer, leaving the other vehicles uninsured, or underinsured under a different policy, ³⁴⁸ and being able to claim uninsured or underinsured motorist benefits from the first insurer even though no premium was ■ paid to the first insurer for coverage of the other vehicles. An interpretation of the Insurance Code that would allow this would be unreasonable. Comer, 419 Md. at 98 ,18 A.8d at 885.

Our holding in Comer, id. at 100 , 18 A.3d at 836 , was informed by the Court of Special Appeals’s decision in Powell v. State Farm Mut. Auto. Ins. Co., 86 Md.App. 98 , 585 A.2d 286 (1991).

Specifically, in Powell, id. at 100,115, 101 , 585 A.2d at 287, 294 , the Court of Special Appeals concluded that an owned but uninsured exclusion was authorized by IN § 19-509(f)(l)’s predecessor. 14 In that case, Kenneth Powell (“Mr. Powell”) was injured in a motor vehicle accident while driving his wife (“Mrs. Powell”)’s vehicle. See id. at 100, 585 A.2d 286 -87. Mrs. Powell’s vehicle was covered under a policy with State Farm, which included $20,000/$40,000 in UM/UIM coverage. See id. at 100 , 585 A.2d 286 -87.

Mr. Powell’s vehicle, also covered under a policy with State Farm, included $100, 000/$300,000 in UM/UIM coverage. See id. at 100 , 585 A.2d at 287 . Following the accident, Mr. Powell submitted a claim to State Farm under the policy covering his vehicle. See id. at 100 , 585 A.2d at 287 .

State Farm denied the claim, relying on the following exclusion contained in the policy: THERE IS NO COVERAGE: * * * * ⅝ ⅝ 2. FOR BODILY INJURY TO YOU ... WHILE OCCUPYING ... A MOTOR VEHICLE OWNED BY YOU, YOUR SPOUSE OR ANY RELATIVE, and which is not insured under the liability coverage of this policy.

Id. at 100 , 585 A.2d at 287 (emphasis in original). Mr. Powell contended that the exclusion was invalid, because, as the named insured on the policy, Mr. Powell had coverage that followed him and applied to any vehicle he drove. See id. at ³⁴⁹ 100-01 , 585 A.2d at 287 . The Court of Special Appeals disagreed, explaining: We do not believe the statute, by extending coverage to the insured when involved in any accident, enlarged the class of “insured motor vehicles” under policies of insurance.

Thus, when [Mr. Powell’s] policy’s language excludes coverage for a vehicle owned by the named insured or his spouse and which was not insured under the liability coverage of “this policy,” it was referring to vehicles not described in the policy of insurance at issue, such as [Mrs. Powell’s vehicle]. The clause provides that the uninsured motorist coverage under Mr. Powell’s policy does not apply if he was occupying a motor vehicle owned by his wife that was not described as an insured vehicle in his policy. Id. at 102-08 , 585 A.2d at 288 (emphasis in original). Thus, the Court of Special Appeals concluded that the policy clearly excluded coverage for vehicles owned by the insured or a member of the insured’s family and not covered under the policy.

See id. at 103 , 585 A.2d at 288 . As to the policy’s compliance with IN § 19—509(f)(l)’s predecessor, the Court of Special Appeals observed that “when a policy provision is not in conflict with the statute, that provision will be enforced, the statute’s underlying purpose notwithstanding.” Id. at 107, 585 A.2d at 290 (brackets, citation, and internal quotation marks omitted). The Court of Special Appeals noted that the underlying policy considerations for the exclusions contained in IN § 19—509(f)(l)’s predecessor would be contravened by Mr. Powell’s interpretation of the statute as granting coverage to the insured regardless of which vehicle was involved in the accident: The obvious purpose of the policy exclusion as to uninsured vehicles is to prohibit a person from purchasing insurance for one car only and utilizing that coverage as to other vehicles owned by the insured through the “in any accident” provision of the policy. This type of prohibition is not against public policy.

To apply its language as [Mr. Powell] urges would invite multi-vehicle families to insure only one vehicle. It would play havoc with premium determinations ³⁵⁰ and otherwise be detrimental to the process of providing liability protection to the motorists, and others, of Maryland. [Mr. Powell]’s interpretation of the clause, if adopted, would be, as we see it, contrary to public policy. Id. at 107-08, 585 A.2d at 290 . The Court of Special Appeals was unpersuaded by Mr. Powell’s contention that his wife’s vehicle was not “uninsured” for the purpose of the exclusion: To hold as [Mr. Powell] also urges, ie., that [Mrs. Powellj’s vehicle was not uninsured because it was covered under another policy, would be to permit an owner to buy excess coverage under one policy for one vehicle at a relatively small premium and coverage under a separate policy for his other vehicles at a lesser cost, and have the excess coverage of the first policy apply to the vehicles covered under the subsequent policies.

Id. at 110 , 585 A.2d at 291 (emphasis in original) (footnote omitted). The Court of Special Appeals found support for its holding in the legislative intent behind IN § 19-509(f)(l)’s predecessor. See Powell, 86 Md.App. at 111 , 585 A.2d at 292 . Indeed, the Court of Special Appeals observed that the General Assembly’s addition of the “owned but uninsured” exclusion following this Court’s decision in Gartelman evinced the General Assembly’s intent “that the exclusion extend to vehicles owned by a named insured’s spouse that are not covered under the policy at issue.” Powell, 86 Md.App. at 111 , 585 A.2d at 292 .

Thus, the Court of Special Appeals declined to “in-creas[e] the minimum required coverage by judicial fiat.” Id. at 118 , 585 A.2d at 293 . In Gonzalez v. Md. Auto. Ins. Fund, 628 A.2d 101, 101-02 (D.C. 1993), a case factually similar to the instant case, the District of Columbia Court of Appeals (“DC Court of Appeals”) relied on Powell in concluding that a taxicab was an “uninsured motor vehicle” for purposes of an owned but uninsured UM/UIM coverage exclusion.

The insured, Mario Gonzalez (“Gonzalez”), owned a taxicab and a personal vehicle, which he insured under different policies. See id. at 101 . Gonzalez maintained only liability coverage on the taxicab, but ³⁵¹ carried UM/UIM coverage under his policy with the MAIF on his personal vehicle. See id.

Gonzalez sustained personal injuries when an uninsured motorist struck his taxicab. See id. He subsequently filed a claim for coverage with the MAIF, which denied his claim on the grounds that the taxicab was an “uninsured motor vehicle.” See id. at 101-02 . Applying Maryland law, the DC Court of Appeals agreed with the MAIF, concluding that, “under the reasoning of the Powell [Cjourt, the exclusion from [Gonzalezjs MAIF policy of his taxi is not contrary to public policy and thus applies.” Gonzalez, 628 A.2d at 108 .

Analysis Here, as to the overall question presented in this case, we hold that an insurer of a personal motor vehicle liability insurance policy, which includes PIP coverage, is not responsible, as a result of the application of the personal motor vehicle liability insurance policy’s owned but not insured exclusion, for PIP coverage for injuries that the insured sustained while driving a taxicab owned by the insured but not covered by the personal motor vehicle liability insurance policy. Stated in terms of this case, we hold that the third exclusion in State Farm’s policy applies and that State Farm is not responsible for PIP coverage for the injuries that Bundu-Conteh sustained while driving the taxicab, which was owned by Bundu-Conteh, but not insured with State Farm; ie., Bundu-Conteh is not entitled to PIP coverage under the State Farm policy. As to the more specific issues underlying that predominant holding, we conclude that: (1) a taxicab is a “motor vehicle” for purposes of the owned but uninsured exclusion from PIP coverage set forth in IN § 19—505(e)(l)(ii) and the payment of benefits under IN § 19—513(d)(l)(i); (2) “uninsured motor vehicle” for purposes of IN § 19-505(c)(l)(ii) means uninsured for PIP coverage, such that a motor vehicle, including a taxicab, that is not insured for PIP coverage is an “uninsured motor vehicle” for purposes of IN § 19—505(c)(1)(ii); and (3) the third exclusion in the State Farm policy in this case is authorized by the owned but ³⁵² uninsured exclusion from PIP coverage set forth in IN § 19-505(c)(l)(ii). In this case, we are confronted with a circumstance in which broad application of the statutorily provided definition of “motor vehicle” in IN § 19~501(b), and specifically IN § 19—601(b)(2) (ii)’s exclusion of a taxicab as a “motor vehicle,” potentially renders other sections of Subtitle 5 of Title 19 of the Insurance Article illogical.

To discern the meaning of the term “motor vehicle” as it is defined in IN § 19—501(b) and as it is used in IN § 19—505(c)(l)(ii) (“uninsured motor vehicle”) and IN § 19—513(d)(l)(i) (“motor vehicle”), we apply the rules of statutory construction. We begin by examining the language of IN § 19-501(b), which provides: (b) Motor vehicle.— (1) “Motor vehicle” means a vehicle, including a trailer, that is operated or designed for operation on a public road by any power other than animal or muscular power. (2) “Motor vehicle” does not include: (i) a bus as defined in § 11-105 of the Transportation Article; or (ii) a taxicab as defined in § 11-165 of the Transportation Article. By its language, IN § 19-501(b) excludes certain vehicles— namely, buses and taxicabs—that would otherwise be considered “motor vehicles” under IN § 19-501(b)(l)’s definition, because a bus or a taxicab certainly is a vehicle “that is operated or designed for operation on a public road by [] power other than animal or muscular power.” We observe, however, that IN § 19-501(b)’s definition of “motor vehicle” and its exclusion of a taxicab as a “motor vehicle” differ from the ordinary, commonsense meaning and understanding of the term “motor vehicle.” See Bottini, 450 Md. at 195 , 147 A.3d at 382 (“To ascertain the natural and ordinary meaning of [a term], we look to dictionary definitions as a starting point.” (Citation and internal quotation marks omitted)).

Merriam-Webster defines a “motor vehicle” as “an automotive vehicle not operated on rails; especially: one with ³⁵³ rubber tires for use on highways[.]” Motor Vehicle, Merriam-Webster (2016), http://www.merriam-webster.com/dictionary/ motor+vehicle [https://perma.cc/2RJX-P5JH]. And, Black’s Law Dictionary defines a “motor vehicle” as “[a] wheeled conveyance that does not run on rails and is self-propelled, especially] one powered by an internal-combustion engine, a battery or fuel-cell, or a combination of these.” Motor Vehicle, Black’s Law Dictionary (10th ed.' 2014). Thus, under the ordinary meaning of the term “motor vehicle” and even under IN § 19-501(b)(l)’s basic definition of “motor vehicle,” a taxicab is a motor vehicle. Moreover, the ordinary meaning of “motor vehicle” closely aligns with the definition of “motor vehicle” in TR § ll-135(a), which does not contain any exclusions for taxicabs or buses as IN § 19-501(b) does.

For purposes of the Maryland Vehicle Law, TR § ll-135(a) defines a “motor vehicle” as follows: (a) In general.—(1) “Motor vehicle” means ... a vehicle that: (i) Is self-propelled or propelled by electric power obtained from overhead electrical wires; and (ii) Is not operated on rails. (2) “Motor vehicle” includes a low speed vehicle[ 15 ] As stated above, IN § 19-501(b) provides a similar definition of the term “motor vehicle,” but excludes certain specified vehicles that would otherwise be considered “motor vehicles,” ie., buses and taxicabs. Significantly, the Insurance Article does not define the term “taxicab,” but instead references the definition in TR § 11-165. See IN § 19—501(b)(2)(ii) (“ ‘Motor vehicle’ does not include ... a taxicab as defined in § 11-165 of the Transportation Article,”).

TR § ll-165(a) defines “taxicab” as follows: (a) In general.—“Taxicab” means, except as provided in subsection (b) of this section, a motor vehicle for hire that: ³⁵⁴ (1) Is designed to carry seven or fewer individuals, including the driver; and (2) Is used to accept or solicit passengers for transportation for hire between those points along highways in this State as the passengers request. (Emphasis added), 16 In other words, under TR § 11—165(a), a taxicab is a “motor vehicle,” just as it is under the plain meaning of the term. Thus, IN § 19-501(b)’s definition of “motor vehicle,” with the exclusion of a taxicab as a motor vehicle, sharply conflicts with the ordinary meaning of the term “motor vehicle” and the definition of a “taxicab” in TR § ll-165(a). Considering these differing definitions, it is apparent that the term “motor vehicle” is subject to more than one reasonable interpretation, specifically as it pertains to taxicabs, and thus is ambiguous.

Indeed, in excluding taxicabs from categorization as “motor vehicles,” IN § 19—501(b)(2)(ii) specifically references TR § 11-165, in which a “taxicab” is defined as a “motor vehicle.” Furthermore, importantly, the provisions of the Insurance Article relevant to the present case, IN § 19—505(c)(l)(ii) and IN § 19—513(d)(l)(i), discuss exclusions and benefits only in the context of “motor vehicles.” IN § 19—505(c)(1)(ii) provides: An insurer may exclude from the coverage described in this section benefits for: [[Image here]] (ii) the named insured or a family member of the named insured who resides in the named insured’s household for an injury that occurs while the named insured or family member is occupying an uninsured motor vehicle owned by: 1. the named insured; or ³⁵⁵ 2. an immediate family member of the named insured who resides in the named insured’s household. (Emphasis added). And IN § 19-513(d)(l)(i) provides: The insurer under a policy that contains the coverages described in §§ 19-505 and 19-509 of this subtitle shall pay the benefits described in §§ 19-505 and 19-509 to an individual insured under the policy who is injured in a motor vehicle accident: (i) while occupying a motor vehicle for which the coverages described in §§ 19-505 and 19-509 of this subtitle are not in effect; (Emphasis added). And, IN § 19-505(a)(l)(i) provides that PIP coverage shall be provided, in pertinent part, to “the first named insured ... who is injured in any motor vehicle accident, including an accident that involves an uninsured motor vehicle or a motor vehicle the identity of which cannot be ascertained!.]” (Emphasis added).

This definitional conundrum becomes problematic in circumstances, such as those of the instant case, wherein an individual occupying a taxicab or other non-motor vehicle seeks to avail him- or herself of the protections provided by IN §§ 19-505 and 19-513, ie., PIP coverage. Although the definition of “motor vehicle” under IN § 19-501(b) expressly excludes taxicabs, we observe that, when that definition is applied to other provisions of the Insurance Article—namely, IN §§ 19-505 and 19-513—it produces an unreasonable and indeed illogical result. Were we to exclude taxicabs from classification as “motor vehicles” for purposes of IN §§ 19-505 and 19-513, any passenger who is injured while riding in a taxicab and who personally carries PIP coverage through his or her own motor vehicle liability insurance policy would be unable to make a claim for PIP coverage. This is so because, as discussed above, a taxicab is not required to obtain PIP coverage; accordingly, because PIP coverage is not in effect, IN § 19-513(d)(l) applies, IN § 19-513(d)(l) provides: The insurer under a policy that contains [PIP and UM/ UIM] coverages ... shall pay the benefits ... to an individ ³⁵⁶ ual insured under the policy who is injured in a motor vehicle accident: (i) while occupying a motor vehicle for which [PIP and UM/UIM] coverages ... are not in effect; or (ii) by a motor vehicle for which [PIP and UM/UIM] coverages ... are not in effect as a pedestrian!.] (Paragraph breaks omitted).

In other words, for an insured’s PIP coverage to follow the insured, the insured would need to be injured in a motor vehicle accident while