In Gibson v. State Farm Mut. Auto. Ins. Co., the Third Circuit confronted an issue of Pennsylvania law regarding underinsured motorist coverage. Under 75 Pa.C.S. § 1734, an insured Pennsylvanian can reduce her premium by opting for a lower amount of UIM so long as she makes a “request in writing.” Here, the insured had signed an application in which she selected lower UIM coverage in her application, even though she did not sign a form that her insurer required in order to select the lower coverage. After the insured was involved in a serious car crash, she went back to the insurer and signed that required form. She then sued her insurer, claiming that the waiver was invalid. The Third Circuit disagreed, holding that the insured’s signed writing, which selected the lower UIM limit, satisfied the Pennsylvania statute.