The County of McLean v. States Self-Insurers Risk Retention Group, Inc.

Alan Beaman, whose murder conviction was reversed by Illinois Supreme Court, which concluded that State unlawfully withheld exculpatory evidence, filed suit in federal court against county and county officials for Section 1983 violation and state-law tort claims, including malicious prosecution."Occurrence" of Beaman's "personal injury" within meaning of insurance policy of county and county officials was his arrest and prosecution, not his exoneration. Because Beaman's alleged "personal injury" occurred outside the policy period, court erred in granting summary judgment for county and county officials. (POPE and HOLDER WHITE, concurring.)