The opinion in Geist v. State Farm Mutual Automobile Insurance, 49 F. 4th 861 (3rd Cir. Sept. 29, 2022), was authored by Chief Judge Marjorie Rendell of the U.S. Court of Appeals for the Third Circuit. Miranda Geist was injured in an automobile collision. After settling a tort claim against the driver and discovering that the driver’s insurance coverage could not fully compensate her for her injuries, she sought to recover underinsured motorist (UIM) benefits under a personal automobile insurance policy issued to her parents, Kevin and Karen Iwasaki (the policy).

Her parents’ insurer, State Farm Mutual Automobile Insurance Co. (State Farm), offered her up to $100,000 in benefits, but Geist maintained that she was entitled to up to $200,000 in benefits because State Farm failed to seek a waiver to provide a UIM coverage limit below the bodily injury coverage limit when her father added a new vehicle to the policy.