Melissa Greene won summary judgment for Allstate, securing an opinion that Allstate’s UM policy limits were “reduced by” limits despite Plaintiff’s assertion the limits were “added on”. The trial court found the Plaintiff affirmatively selected “reduced by” limits. Moreover, the trial court found it was without consequence that the selection/rejection occurred prior to the effective date of the 2008 “added on” statutory amendment, because that specific amendment did not impact the right to affirmatively choose lesser UM coverage.  The Court of Appeals affirmed the trial court’s ruling and the Georgia Supreme Court denied Plaintiff’s Petition for Certiorari.