This Note traces the development of UIM coverage in North Carolina by examining the statutory and judicial history preceding Ray v. Atlantic Casualty Insurance Co. This Note then analyzes the rationale behind the court's holding in Ray and compares the decision to cases on point in other jurisdictions. Next, this Note examines the holdings in Ray and Harris v. Nationwide Mutual Insurance Co. in light of the legislative purpose behind the Motor Vehicle Safety and Financial Responsibility Act. And finally, this Note addresses the ramifications of Ray, including the effect of the decision and any remaining questions.
Paul J. Osowski, Underinsured Motorist Coverage: North Carolina's Multiple Claimant Wrinkle - Ray v. Atlantic Casualty Insurance Co., 17 Campbell L. Rev. 147 (1995).