Brown v. Advocate Health and Hospitals Corporation

Defendant hospital violated court order, in medical malpractice action, by refusing to produce insurance-related documents for in camera inspection. Hospital objected to producing its insurance policies on grounds that it is self-insured. Hospital disclosed $12.5 million in coverage for plaintiff's claim pursuant to a self-insured retention and trust, but refused to produce trust agreement or related documents, and court then held hospital in "friendly contempt" and imposed a $100 fine. Court did not abuse its discretion in ordering in camera inspection of insurance-related documents. (LAMPKIN, concurring; GORDON, dissenting.)