Bumbarger v. Peerless Indemnity Insurance, 93 A.3d 872

Helen Bumbarger purchased an auto policy from Peerless (May 17, 2007) covering two vehicles and signed a valid written waiver rejecting stacked UM/UIM limits.
Helen bought a third vehicle (1995 Ford F-150) July 24, 2007 and the agent added it to the policy the same day by endorsement to the Declarations; a fourth vehicle was added later and reflected on an amended declarations page.
Helen was injured on December 3, 2009 driving the third vehicle in a collision with an uninsured motorist and submitted a UM claim seeking stacked limits.
Peerless argued the original May 17, 2007 stacking waiver remained effective; the Bumbargers argued a new waiver was required when the new vehicles were added.
The trial court granted summary judgment to the Bumbargers, concluding the third vehicle had been added by endorsement (not via the after-acquired-vehicle clause) so Sackett I required Peerless to obtain a new waiver; Peerless appealed and the Superior Court, sitting en banc, affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether insurer must obtain a new UM stacking waiver when a new vehicle is added to an existing multi-vehicle policy	Bumbarger: vehicle was added by endorsement to the Declarations, triggering Sackett I; Peerless needed to obtain a new signed waiver or default to stacked limits	Peerless: coverage for newly acquired vehicles is governed by the policy’s after-acquired-vehicle clause (infinite duration); no new waiver required	Held: Because the third vehicle was added by endorsement to the Declarations, the after-acquired clause was not triggered and Sackett I requires a new waiver; none was obtained, so stacked UM applies

Sackett v. Nationwide Mut. Ins. Co., 919 A.2d 194 (Pa. 2007) (Sackett I) (holding insurer must secure a new stacking waiver when a new vehicle is added to a policy absent language extending pre-existing waiver)
Sackett v. Nationwide Mut. Ins. Co., 940 A.2d 329 (Pa. 2007) (Sackett II) (clarifying that after-acquired-vehicle clauses can preserve waivers when such clauses unambiguously extend coverage and are of indefinite duration)
Sackett v. Nationwide Mut. Ins. Co., 4 A.3d 637 (Pa. Super. 2010) (Sackett III) (applying Sackett I where addition by endorsement placed vehicle on the Declarations, requiring a new waiver)
Shipp v. The Phoenix Ins. Co., 51 A.3d 219 (Pa. Super. 2012) (distinguishing replacement vehicles from added vehicles and holding no new waiver needed for replacement vehicles that do not change coverage)
Merriweather v. Philadelphia Newspapers, Inc., 684 A.2d 137 (Pa. Super. 1996) (summary judgment standard)