United States Fidelity & Guaranty Co. v. Reid

The issue in this case is whether uninsured motorist carriers (UMC) deserve special treatment not accorded other defendants in the application of rules for service and the privilege of dismissal and renewal under OCGA § 9-2-61. Because I find no justification for treating UMCs differently, I concur in the affirmance of the Court of Appeals. I write separately because the majority’s opinion fails to clarify the conflict between Bohannon v. J. C. Penney Cas. Ins. Co.1 and Hobbs v. Arthur,2 the issue for which certiorari was granted, and instead relies upon the difficult distinction between void…