Philadelphia Indemnity Ins. Co. v. Chicago Title Ins. Co.

In action by plaintiff-excess general liability insurance company seeking declaration that defendant-title insurance company had duty to defend insured on all claims in underlying action under circumstances where title insurance policy provided limited coverage for claims involving defects in title or lien priority and/or other claims adverse to insured’s title, and where underlying lawsuit alleged actions that were and were not covered by title insurance policy, Dist. Ct. erred in finding that defendant had duty to defend entire lawsuit under “complete defense” rule. Complete defense rule does not apply to title insurance policies, which seek to insure only limited range of losses related to defects in title. Moreover, Ct. observed that Ill. Supreme Ct. had only applied complete defense rule in context of general liability insurance policies.