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

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

Leachman had purchased a $300,000 combined single limitliability automobile insurance policy from Progressive. The formexplained that increased coverage was available, and instructedinsureds to select the amount of coverage they desired. Insuredsalso were instructed to acknowledge that they had selected orrejected UIM coverage. Leachman selected UIM coverage, and signedthe form at the bottom, noting that the UIM coverage was lower thanhis liability coverage.