Harris v. Criterion Ins. Co
In Harris v. Criterion Ins. Co., 222 Va. 496, 281 S.E.2d 878 (Va. 1981), the Supreme Court of Virginia found the computer posting of a late premium to a terminated account did not affect the previous cancellation of the policy.
It determined that the obligation to return the unearned premium created a debtor-creditor relationship rather than affecting the cancellation of the policy. 281 S.E.2d at 882.