Plaintiff was a passenger in a vehicle owned by the defendant’s insured that was involved in an auto ac- cident with an underinsured driver. She received $100,000 from the adverse driver’s insurance carrier and UM benefits of $150,000 from her driver’s carrier. However, she sued her driver’s umbrella insurer for additional UIM benefits. The umbrella policy provided UIM coverage for the named insured and family members which did not include plaintiff. The trial court dismissed the complaint with prejudice.

The First District affirmed. In Illinois, umbrella policies and primary auto policies are distinct. Under the Illinois Insurance Code, carriers may provide UM and UIM coverage, but they are not required to so do. There is no statutory or public policy requirement obligating a car- rier to provide UIM coverage under an umbrella policy. Pang v. Farmers Insurance Group, 2014 IL App (1st) 123204-U.