Citizens Insurance Company of America v. Mullins Food Products, Inc.

In an insurance coverage matter arising out of claims against an insured for violations of the Illinois Biometric Information Privacy Act, the Seventh Circuit considered whether the district court correctly concluded that there was no duty to defend or indemnify under the policy exclusions for the access or disclosure of confidential or personal information and the recording and distribution of material or information in violation of the law. The Seventh Circuit vacated and remanded, finding that the access or disclosure exclusion, found in only two of the three applicable policies, barred coverage but that the statutory violation exclusion did not bar coverage. (BRENNAN and KOLAR, concurring)