In Zelinski v. Townsend, 163 Md. App. 211, 878 A.2d 623 (2005), cert. granted, Harleysville Mut. Ins. Co. v. Zelinski, 389 Md. 398, 885 A.2d 823 (2005), the Court considered whether a named driver exclusion in a commercial policy was valid. The Zelinskis were injured when their vehicle was struck by a truck driven by Robert Townsend, an employee of Mac's Septic Service. After the Zelinskis obtained judgments against Townsend, they filed for a writ of garnishment directed to the Harleysville Mutual Insurance Company, which insured Mac's Septic Service under a commercial motor vehicle policy. The policy was amended in September 2000 to exclude Townsend as a covered driver after his license was suspended. Id. at 214. The circuit court determined that the named driver exclusion controlled and dismissed the writ of garnishment against Harleysville Mutual. On appeal, the Zelinskis asserted that a named driver exclusion in the commercial policy was invalid in light of the legislative history of the named driver exclusion as codified at Ins. 27-606. In 1989, the General Assembly repealed and reenacted the named driver exclusion, but limited its application to "automobile insurance policies issued in the State to a resident of a household, under which more than one individual is insured." Zelinski, 163 Md. App. at 216. The Court agreed and held that the named driver exclusion in the commercial motor vehicle policy was void, and remanded the case for a determination of the amount of coverage under the policy. The Court explained that "Maryland law 'certainly does not require insurance companies to provide for coverage greater than that mandated by statute.'" Id. at 217. The Court acknowledged that the Court of Appeals has said that not all exclusions in an automobile policy are invalid only to the extent of the statutory minimum, but concluded that the named driver exclusion in Zelinski could limit the carrier's liability to the statutory minimum coverage, far less than the full policy amount, if the policy exclusion was "(1) accompanied by a reduction in premiums, or (2) issued at the request of the insured to avoid an increase in premiums." Id. at 218.