Court dismisses negligence lawsuit against State Farm over fatal USPS truck crash

A federal judge has dismissed a negligence lawsuit against State Farm Mutual Automobile Insurance Company, ruling that the insurer cannot be held liable for a fatal truck crash that killed five members of the Godinez family in Colorado. The decision, issued on March 11, 2025, by Judge Nina Y. Wang of the United States District Court for the District of Colorado, found that State Farm’s alleged failure to notify federal regulators about an expired insurance policy was too far removed from the events leading to the accident to establish legal causation.

The case, brought by Christian and Abigail Godinez, sought to hold State Farm accountable for the June 13, 2022, crash, arguing that the insurer’s failure to report the nonrenewal of a truck insurance policy had set off a chain of events that led to the collision. The court, however, found that the plaintiffs’ theory of liability was too speculative and dismissed the claim with prejudice, meaning it cannot be refiled.

A devastating collision

The accident occurred on Interstate 25 as Aaron Godinez was driving his parents, his fiancée, and their infant daughter back to Wyoming after a weekend in Denver. Their vehicle was struck by a mail-hauling semi-truck, driven by Jesus Puebla, an unlicensed trucker employed by Lucky 22, Inc., a subcontractor for Caminantes Trucking, which had a contract with the United States Postal Service (USPS).

All five family members died at the scene.

A jury later convicted Puebla of vehicular homicide, reckless driving, and operating a commercial vehicle without a valid commercial driver’s license.

At the time of the crash, Lucky 22 was a subcontractor for Caminantes Trucking, which in turn was hauling mail for USPS. The lawsuit alleged that both trucking companies had long histories of safety violations and regulatory noncompliance.

The insurance dispute

State Farm became involved in the case because it had previously issued an insurance policy for Caminantes Trucking, including a Form MCS-90 - a federal document that ensures commercial trucks meet minimum financial responsibility requirements under Federal Motor Carrier Safety Administration (FMCSA) regulations.

However, in February 2020 - more than two years before the crash - State Farm declined to renew Caminantes’ insurance policy, citing a history of safety violations. The plaintiffs alleged that State Farm failed to notify the FMCSA of the nonrenewal, as required by federal regulations. Had State Farm provided the notification, plaintiffs argued, the FMCSA would have revoked Caminantes’ operating authority, preventing its trucks from being on the road.

Plaintiffs contended that this failure to notify was a direct cause of the crash, as it allowed Caminantes and its subcontractor, Lucky 22, to continue operating unsafe vehicles, including the one involved in the fatal accident.

State Farm’s defense and the court’s ruling

State Farm moved to dismiss the case, arguing that:

• It had no legal duty to the plaintiffs.
• Its failure to notify the FMCSA was not the direct cause of the crash—the accident could have occurred regardless of whether Caminantes retained insurance.
• Other defendants, including Caminantes, Lucky 22, and USPS, played far greater roles in causing the accident.

Judge Wang agreed with State Farm, ruling that the plaintiffs failed to establish causation. In negligence cases, plaintiffs must prove both factual causation (“but-for” causation) and proximate causation (foreseeability and substantial factor analysis).

The judge found that:

• The plaintiffs failed to show that State Farm’s actions directly caused the crash. Caminantes had over two years to obtain new insurance or comply with FMCSA regulations, meaning State Farm’s alleged failure was not the decisive factor.
• The argument that FMCSA would have revoked Caminantes’ operating authority was speculative - the agency does not automatically revoke a trucking company’s license over a single uninsured vehicle.
• Even if Caminantes had been shut down, the same accident could have happened - given that Lucky 22, Caminantes, and USPS were allegedly violating multiple safety rules.
• USPS’s failure to properly vet its contractors played a far more direct role in allowing the unsafe truck and unlicensed driver to operate on federal contracts.

Given these issues, the judge dismissed the claim with prejudice, barring the plaintiffs from amending their complaint or refiling the case against State Farm.

Implications for insurance and trucking liability

The decision sets an important precedent regarding the limits of insurer liability in commercial trucking accidents.

For insurance companies:

• The ruling clarifies that an insurer’s failure to report a policy nonrenewal does not automatically create liability—especially when significant time has passed, and other parties have had opportunities to comply with regulations.
• MCS-90 endorsements do not indefinitely bind insurers to liability if a policy has expired.

For trucking companies and federal contractors:

• The case highlights the need for USPS and other agencies to rigorously vet trucking subcontractors. Caminantes and Lucky 22 had extensive safety violations, yet were still hauling U.S. mail at the time of the crash.
• Uninsured and unregulated trucking operations remain a significant safety risk, particularly when subcontracting layers obscure accountability.

What comes next?

Although State Farm is now removed from the lawsuit, the wrongful death claims against Caminantes Trucking, Lucky 22, USPS, and individual defendants remain active. Plaintiffs will likely shift their focus to those defendants, arguing that their direct negligence in hiring, training, and supervising drivers led to the deadly crash.

For the Godinez family, the legal battle is far from over. However, the court’s rejection of the claim against State Farm marks a significant shift in the case, narrowing potential sources of liability while reinforcing the challenges of holding insurers accountable for lapses in regulatory reporting.

With commercial trucking accidents and regulatory enforcement under increasing scrutiny, this case raises critical questions about the oversight of subcontracted federal freight carriers - and whether agencies like USPS are doing enough to ensure that only safe, properly insured trucks operate on government contracts