Universal North America Insurance Company v. Galloway, 4:16-cv-03075

Universal issued a homeowners policy to Matthew and Betty Galloway covering personal liability for bodily injury caused by an "occurrence" during the policy period (4/11/2016–4/11/2017).
On June 3, 2016, 20‑month‑old LG (son of Deborah Fromme) was run over and killed by a vehicle operated by Amanda Galloway.
The vehicle was titled in Amanda and Matthew Galloway’s names; Amanda lived on the insureds’ property and was a household member and relative of the insureds.
Universal sued for a declaratory judgment that no coverage exists under the homeowners policy for Matthew, Betty, Amanda, or Deborah (as guardian of LG) for the June 3, 2016 incident.
Defendants failed to answer; entries of default were entered and Universal moved for default judgment under Fed. R. Civ. P. 55(b)(2).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Effect of default	Defendants’ defaults admit the complaint facts, so court should accept allegations.	No answer — no defense raised.	Default admits well‑pleaded facts; court treats allegations as established.
Whether Amanda is an “insured” under the homeowners policy	Amanda was a relative and household member of the named insureds and thus qualifies as an insured.	No answer.	Court finds Amanda is an insured.
Whether vehicle ownership/operation by an insured triggers an exclusion	The policy excludes liability/medical payments for bodily injury arising out of ownership, maintenance, use of motor vehicles owned or operated by an insured.	No answer.	Court holds the motor‑vehicle exclusion applies because the incident arose from use of a vehicle owned/operated by an insured.
Coverage for Matthew, Betty, Amanda, and Deborah (guardian of LG)	No coverage exists under the homeowners policy for injuries/death from the June 3, 2016 motor vehicle incident.	No answer.	Court grants default judgment: no coverage exists for Matthew, Betty, Amanda, or Deborah (as guardian) for the incident.

Ryan v. Homecomings Fin. Network, 253 F.3d 778 (4th Cir. 2001) (default admits well‑pleaded factual allegations)
Cook v. State Farm Auto. Ins. Co., 376 S.C. 426 (S.C. Ct. App. 2008) (insurance policies construed as contracts under contract law)
Torrington Co. v. Aetna Cas. & Sur. Co., 264 S.C. 636 (S.C. 1975) (courts may not rewrite policy terms to create coverage)