American Service Insurance v. Miller

(Court opinion corrected 10/20/14.) Insurer filed declaratory judgment action against insured for sued filed against insured for auto accident in which insured struck a bicyclist. Court's award of Rule 137 and Rule 219 sanctions against insurer (but not against insurer's counsel) for failure to produce correct insurance policy was appropriate ($20,000 policy limit, plus interest, and $60,000 in attorney's fees and $3900 in litigation expenses), and court found no evidence of intentional concealment or willful misconduct by insurer to warrant further sanctions. (STEWART and CATES, concurring.)