The Supreme Court of South Carolina has issued its decision in Progressive Casualty Ins. v. Leachman, which questioned Progressive's use of UIM selection forms. The court found that such forms constituted meaningful offers and that, in making such an offer, it is sufficient for an insurer to offer an insured all of the coverage amounts an insurer is authorized to sell.

Leachman was seriously injured when he was hit by an automobile while taking a walk. In addition to UIM coverage, for which Progressive paid $100,000, he also sought additional coverage up to the amount of his liability coverage.

Leachman had purchased a $300,000 combined single limit liability automobile insurance policy from Progressive. The form explained that increased coverage was available, and instructed insureds to select the amount of coverage they desired. Insureds also were instructed to acknowledge that they had selected or rejected UIM coverage. Leachman selected UIM coverage, and signed the form at the bottom, noting that the UIM coverage was lower than his liability coverage.

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