Many personal policies of insurance define the term “auto” as a private passenger vehicle designed for operation principally on public roads. While no Georgia courts have decided the issue, courts in other jurisdictions have determined that a golf cart is not an “auto” under private auto policies of insurance. See Bailey v. Netherlands Ins. Co., 615 F.Supp.2d 1332 (M.D. Fla. 2009); Progressive Casualty Insurance Co. v. Dunn, 665 A.2d 322 (Md. 1995); Herr v. Grier, 671 A.2d 224, 226 (Pa. Super. Ct. 1996); Progressive Cas. Ins. Co. v. McCrea, 2010 WL 2108965 (Conn. Super. Ct. 2010); Jennings v. Midville Gold Club, Inc., 636 A.2d 707, 708 (R.I. 1994); Seaboard Fire & Marine Ins. Co. v. Gibbs, 392 F.2d 793, 794 (4th Cir. 1968).
The reasoning of these cases is strong. An unmodified, run-of-the-mill golf cart, is not made for use “principally” upon public roadways, particularly in light of the fact that its maximum speed is about 25 miles per hour and it lacks the safety features necessary for travel on public roadways, including a full windshield, doors, a solid roof, turn signals, and a gear-shifting mechanism. Even though such a case has yet to be decided by a Georgia court, it is likely that a Georgia court would determine that a golf cart is not an “auto” under the standard definition set forth in many policies. As such, it is likely that most automobile liability insurance policies do not provide any coverage for accidents involving golf carts.