Safeco Insurance Co. V. United States Fidelity & Guaranty Co‪.‬

This action arose when Kim Taylor's automobile collided with an automobile driven by Nicholas Calamino and an automobile driven by Richard Vigil and owned by Eugene Vigil. Taylor was insured by USF & G, Calamino was insured by Safeco, and the Vigils were uninsured. After USF & G paid the bulk of Taylor's damages, it sued Calomino, Safeco, and the Vigils on a subrogation theory, and named Taylor an involuntary plaintiff to the extent of her $100 deductible. The trial court dismissed the claim against Safeco. Citing Sellman v. Haddock, 62 N.M. 391, 310 P.2d 1045 (1957), Maurer v. Thorpe, 95 N.M. 286, 621 P.2d 503 (1980), and Campbell v. Benson, 97 N.M. 147, 637 P.2d 578 (Ct. App.1981), the court of appeals reversed and held that due process requires Safeco to be joined as a party defendant. We granted certiorari to clarify the law regarding joinder and naming insurance companies as parties, and regarding the introduction of evidence of a party's insured status.