Illinois Municipal League Risk Management Association v. State Farm Fire and Casualty Company

Illinois Appellate Court
Civil Court
Insurance
Citation
Case Number: 
2016 IL App (1st) 131180
Decision Date: 
Tuesday, February 2, 2016
District: 
1st Dist.
Division/County: 
Cook Co., 2d Div.
Holding: 
Affirmed.
Justice: 
NEVILLE

Clause in umbrella policy that made its coverage apply only after exhaustion of limits of all applicable "insurance and self insurance" is unambiguous and enforceable.  Plaintiff Municipal Association's contract with Village qualifies as self-insurance within meaning of other insurance clause in umbrella policy. Public policy does not make contract unenforceable. (PIERCE and HYMAN, concurring.)