Progressive Direct Insurance Company, Plaintiff v. Bryan Reeves, Defendant.

Summary

The South Carolina Supreme Court answered a certified question from the federal district court, holding that adding Bryan Reeves as a named insured constituted a change to the existing automobile insurance policy under §38-77-350(C). Because the addition is a change, the insurer was not required to make a new offer of underinsured motorist coverage. The court declined to address the second certified question.