On April 27, 2017, the Virginia Supreme Court issued Manu v. GEICO Cas. Co., No. 160852. It affirmed Fairfax County Circuit Court ruling as a matter of law that an uninsured motorist (“UM”) insurer could not be liable under Va. Code §8.01-66.1(D)(1) for failing to pay its policy limits when requested prior to its Plaintiff policy holder obtaining judgment against the Defendant uninsured tortfeasor in a multi-vehicle automobile accident.