Illinois Appellate Court
Civil Court
Insurance
CGL insurer filed declaratory judgment action as to duty to defend its insured, a snow removal service's subcontractor, in slip and fall negligence suit for injuries. Insurer argued that its policy restricted additional coverage endorsements only to construction contracts, and not to snow removal, because the word "construction" appeared as a limiting adjective in endorsement heading in contract . Specific wording in text of endorsement contained no limitation on type of contract covered other than that contract be written. Actual text of policy language and purpose of policy brought suit within policy coverage despite presence of the word "construction" in heading of endorsement section. (CUNNINGHAM and HARRIS, concurring.)