Millers National Insurance Co. v. Taylor Freeman Insurance Agency
In Millers National Insurance Co. v. Taylor Freeman Insurance Agency, 161 Ariz. 490, 494, 779 P.2d 365, 369 (App. 1989), an insurer recovered breach of contract damages from its general agent and subagent after they failed to make a written offer of UIM coverage to one of the insurer's insured. 161 Ariz. at 493, 779 P.2d at 368.
On appeal, the agents argued A.R.S. 20-259.01 did not require them to provide the insured with written notice of the availability of UIM coverage. Id.
The Court explained the agents' argument ignored "the fact that a corporation can only act through its employees and agents," id., and "when an agent undertakes to act for its insurer, the agent must comply with the requirements that are imposed upon its principal," id. at 494, 779 P.2d at 369.