The 1st District Appellate Court recently held that a passenger carrier’s failure to maintain statutorily required minimum uninsured and underinsured motorist coverage did not give rise to a private cause of action against the carrier.Mary Carmichael, the injured person seeking coverage in Carmichael v. Union Pacific Railroad Co., 2018 IL App (1st) 170075 (June 26, 2018), was represented by John Stephan Bishof Jr. Hall Prangle & Schoonveld LLC represented the carrier, Professional Transportation Inc.Carmichael …