Simpson v. State Farm Mutual Automobile Insurance

Appellant Simpson commenced this declaratory judgment action seeking reformation of her auto insurance policy with respondent State Farm to include underinsured motorist coverage. The trial judge denied relief. We affirm.

In February 1985, Simpson received a premium renewal notice accompanied by an insert defining underinsured motorist coverage. She did not purchase the coverage. Nothing indicates State Farm offered the coverage to Simpson after that time.

In December 1986, Simpson changed cars on her policy. At this time, State Farm also raised Simpson’s rental coverage. As a result of these…