Me. Rev. Stat. » Title 24-A
Maine Revised Statutes

Me. Rev. Stat. tit. 24-A, § 2904 (2026)

Judgment creditor may have insurance; exceptions

✓ current as of May 2026
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Whenever any person, including an administrator, executor or guardian, recovers a final judgment against any other person for any loss or damage specified in section 2903, the judgment creditor is entitled to have the insurance money applied to the satisfaction of the judgment by bringing a civil action, in the judgment creditor's own name, against the insurer to reach and apply the insurance money, if when the right of action accrued, the judgment debtor was insured against such liability and if before the recovery of the judgment the insurer had had notice of such accident, injury or damage. The insurer has the right to invoke the defenses described in this section in the proceedings. The provisions of this paragraph and section 2903 do not apply:   [PL 2023, c. 405, Pt. A, §90 (AMD).]
1.  Motor vehicle operated illegally or by one under age.  When the insured automobile, motor vehicle or truck is being operated by any person contrary to law as to age or by any person under the age of 16 years where no statute restricts the age; or  
[PL 1969, c. 132, §1 (NEW).]
2.  Motor vehicle used in race contest.  When such automobile, motor vehicle or trust is being used in any race or speed contest; or  
[PL 1969, c. 132, §1 (NEW).]
3.  Motor vehicle used for towing a trailer.  When such automobile, motor vehicle or truck is being used for towing or propelling a trailer unless such privilege is indorsed on the policy or such trailer is also insured by the insurer; or  
[PL 1969, c. 132, §1 (NEW).]
4.  Liability assumed.  In the case of any liability assumed by the insured for others; or  
[PL 1969, c. 132, §1 (NEW).]
5.  Liability under workers' compensation.  In the case of any liability under any workers' compensation agreement, plan or law; or  
[PL 1989, c. 502, Pt. A, §98 (AMD).]
6.  Fraud or collusion.  When there is fraud or collusion between the judgment creditor and the insured.  
[PL 1969, c. 132, §1 (NEW).]
No civil action shall be brought against an insurer to reach and apply such insurance money until 20 days shall have elapsed from the time of the rendition of the final judgment against the judgment debtors.   [PL 1969, c. 132, §1 (NEW).]
SECTION HISTORY
PL 1969, c. 132, §1 (NEW). PL 1989, c. 502, §A98 (AMD). RR 2021, c. 1, Pt. B, §254 (COR). PL 2023, c. 405, Pt. A, §90 (AMD).
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Notes of Decisions
Cited in 75 cases (5 in the last 5 years), 1971–2026 · leading case: Patrons Oxford Ins. v. Harris, 2006 ME 72 (Me. 2006).
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Patrons Oxford Ins. v. Harris, 2006 ME 72 (Me. 2006). · cites it 7× “24-A M.R.S. § 2904 (2005). Finding no error, we affirm the judgment and remand to the Superior Court for a determination of the reasonableness of the settlement and the damages awarded to Luce, and the alleged existence of collusion.”
Patrick Langevin v. Allstate Ins. Co., 2013 ME 55 (Me. 2013). · cites it 4× “) in favor of Allstate Insurance Company on the Langevins’ reach and apply action, brought pursuant to 24-A M.R.S. § 2904 (2012). The Lan-gevins argue that the court erred in determining that a homeowners insurance policy issued by Allstate to Charles Johnson did not cover the…”
Michaud v. Mut. Fire, Marine & Inland Ins. Co., 505 A.2d 786 (Me. 1986). · cites it 4× “Michaud sued Mutual pursuant to Maine’s reach and apply statute, 24-A M.R.S.A. § 2904 (1974), seeking insurance proceeds to satisfy a judgment recovered against Mutual's insured, Dr.”
Korhonen v. Allstate Ins., 2003 ME 77 (Me. 2003). · cites it 3× “2 [¶ 4] Sally subsequently filed this “reach and apply” suit against Allstate to collect the judgment obtained against Margaret, pursuant to 24-A M.R.S.A. § 2904 (2000). 3 Sally contended that Allstate had a duty to indemnify Margaret under the provisions of the Allstate policy.”
Ashe v. Enter. Rent-A-Car, 2003 ME 147 (Me. 2003). · cites it 2× “§ 2708-A 2 (requiring insurance coverage or a bond on rental vehicles), and 24-A M.R.S.A. § 2904 (2000) (the “reach and apply” statute), authorize his recovery.”
Jacobi v. MMG Ins., 2011 ME 56 (Me. 2011). · cites it 4× “) in favor of Jennifer (Colman) Jacobi in her reach and apply action, 24-A M.R.S. § 2904 (2010), 1 and from the court’s denial of MMG’s cross-motion for summary judgment.”
Sarah G. v. Maine Bonding & Cas. Co., 2005 ME 13 (Me. 2005). · cites it 3× “filed this reach and apply action, 24-A M.R.S.A. § 2904 (2000), against Maine Bonding & Casualty Company.”
Middlesex Mut. Assurance Co. v. Fish, 738 F. Supp. 2d 124 (D. Me. 2010). · cites it 3× “Fish answered and counterclaimed, seeking the full amount of the state court judgment pursuant to Maine’s “reach and apply” statute, 24-A M.R.S.A. § 2904. Answer to Am. Compl.”
Libby v. Concord Gen. Mut. Ins., 452 A.2d 979 (Me. 1982). · cites it 2× “By appropriate motion at each stage of the jury trial Concord challenged the sufficiency of the evidence on the issue of notice required by 24-A M.R.S.A. § 2904 (1969). 1 It was contended that the person to whom notice had been given was not an agent of Concord and therefore…”
Edwards v. Lexington Ins., 507 F.3d 35 (1st Cir. 2007). · cites it 2× “Unable to execute on the judgment against Game Tracker, Edwards (and his wife) sued in the same federal court under Maine’s reach and apply statute, 24-A M.R.S.A. § 2904 (2000), seeking to collect from Lexington Insurance Company, Game Tracker’s insurer.”
Jacques v. Am. Home Assurance Co., 609 A.2d 719 (Me. 1992). · cites it 4× “[1] 24-A M.R.S.A. § 2904 provides, in pertinent part, that: Whenever any person .”
Kelley v. North East Ins. Co., 168 A.3d 779 (Me. 2017). · cites it 4× “) in favor of North East Insurance Company on the reach and apply action she brought pursuant to 24-A M.R.S. § 2904 (2016). The court concluded that the damages awarded to Kelley in the underlying action, see 7 M.”
Show all 75 citing cases →
— Me. Rev. Stat. tit. 24-A, § 2904(1) — 2 cases
Hunnewell v. Liberty Mut. Fire Ins., 588 A.2d 300 (Me. 1991).
United States v. Water Quality Ins. Syndicate, 870 A.2d 121 (Me. 2005).
— Me. Rev. Stat. tit. 24-A, § 2904(6) — 4 cases
Patrons Oxford Ins. v. Harris, 2006 ME 72 (Me. 2006). “24-A M.R.S. § 2904 (2005). Finding no error, we affirm the judgment and remand to the Superior Court for a determination of the reasonableness of the settlement and the damages awarded to Luce, and the alleged existence of collusion.”
Hunnewell v. Liberty Mut. Fire Ins., 588 A.2d 300 (Me. 1991).
Colony Ins. Co. v. Danly, Inc., 755 F. Supp. 2d 219 (D. Me. 2010).
Metro. Prop. & Cas. Ins. Co. v. Googins (Me. Super. Ct 2014).
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