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In the case of Dunleavy v. Mid-Century Ins. Co., No. 2:19-CV-1304 (W.D. Pa. May 19, 2020 Ranjan, J.), Judge Ranjan of the Pennsylvania Western Federal District Court held that the Pennsylvania Supreme Court’s decision in Gallagher v GEICO, in which that court ruled that the household exclusion was no longer valid, did not apply to invalidate a household exclusion in this case where the insured had waived UIM coverage on a motorcycle insured with another carrier.