Allstate Insurance Company v. Craig T. Smith

Summary

The court reversed the Court of Appeals and reinstated summary judgment for Allstate, holding that the insurer had no duty to provide or repeatedly remind Smith about optional underinsured-motorist coverage. The applicable statute required notice only with the insured's first renewal, and Smith's policy had been renewed for decades before the statute applied; in any event, Allstate's renewal form supplied the required information. The court also held that Smith's lengthy relationship with Allstate, without evidence that he sought or relied on coverage advice, did not create an implied duty to inform him. Justice Noble, concurring separately, would emphasize the purchaser's reliance on the insurance agent and questioned the logic of requiring notice at first renewal but not at the initial purchase.