Insurance Law

Underwood v. City of Chicago

Underwood v. City of Chicago
Illinois Appellate Court
Civil Court
Employee Benefits
Citation
Case Number: 
2025 IL App (1st) 231132
Decision Date: 
Friday, February 28, 2025
District: 
1st Dist.
Division/County: 
5th Div./Cook Co.
Holding: 
Affirmed.
Justice: 
ODEN JOHNSON

Plaintiffs, all civic retirees, appealed from a trial court order granting summary judgment in favor of four of the named defendants that were annuity and benefit funds. The appellate court previously affirmed a grant of summary judgment in favor of the City of Chicago. At issue in the appeal was whether the healthcare plan options offered by the funds were insufficient. The appellate court affirmed, consistent with its prior opinion, finding that the plaintiffs did not have a right to receive the additional monetary contributions or guarantee of affordable healthcare requested that they sought in the legal action. (MITCHELL and NAVARRO, concurring)

Artificial Intelligence in Personal Injury Law

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Tort Law Section


1.50 hours MCLE credit, including 1.50 hours Professional Responsibility MCLE credit in the following category: Professionalism, Civility, Legal Ethics, or Sexual Harassment Prevention credit


Original Program Date: Tuesday, February 4, 2025
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­February 12, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Learn how artificial intelligence is revolutionizing personal injury law – from adding efficiency to your law firm practice and delivering excellent results for clients, to streamlining legal research and creating trial exhibits and infographic documents. Attorneys with all levels of practice experience who attend this online program will better understand:
  • The evolution of artificial intelligence in the practice of law;
  • How to leverage artificial intelligence to deliver excellent results for your clients;
  • How the application of AI tools can assist with legal document review and generation;
  • How to use it in drafting demand letters to start settlement discussions;
  • How it can build out medical chronologies almost instantaneously to summarize thousands of pages of records;
  • How AI can help insurance adjusters with claims evaluations;
  • How to build custom GPT bots for personal injury applications;
  • How to use artificial intelligence to identify what biases to consider when preparing for voir dire;
  • How to develop cross-examination strategies for specific witnesses, as well as identify gaps in their reports and medical literature;
  • How to use artificial intelligence to market your practice; and
  • Much more!
A discussion on the ethical and professional issues to consider when using artificial intelligence in your practice is also included.

Program Coordinator/Chat Moderator:
Josh Rohrscheib, Onward Injury Law, Bloomington

Program Speaker:
Michael McCready, McCready Law Injury Attorneys, Chicago


Pricing Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $52.50 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $105
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

Seeing Red: Transforming Anger into Healthy Skills for Healthy Living

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Trusts & Estates Section


1.0 hour MCLE credit, including 1.0 hour Professional Responsibility MCLE credit in the following category: Mental Health and Substance Abuse credit


Original Program Date: Tuesday, January 21, 2025
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­January 27, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Anger comes in many forms – from quiet disappointment to all-consuming rage – and springs from many sources, including perceived provocations, differences of opinion, fragile egos, and more. Don’t miss this opportunity to hear from our speaker, Lynette Hoy, as she explores the best methods for managing anger and coping with angry clients. Attorneys with basic practice experience who attend this online seminar will better understand:
  • The nature and physiology of anger;
  • How to express anger with respect, empathy, and assertiveness using research-based skills;
  • The strategies for coping with anger in personal and professional situations; and
  • Much more.

Program Coordinators:
Kerry R. Peck, Peck Ritchey LLC, Chicago
Colleen L. Sahlas, Law Offices of Hoy & Sahlas, LLC, Oak Brook

Program Chat Moderator:
Colleen L. Sahlas, Law Offices of Hoy & Sahlas, LLC, Oak Brook

Program Speaker:
Lynette J. Hoy, President, Anger Management Institute, Oak Brook
About the Speaker: Lynette Hoy is a Licensed Clinical Professional Counselor in Illinois and a National Certified Counselor. She is a Diplomate, Supervisor, Consultant, and Anger Management Specialist-V with the National Anger Management Association, as well as a Certified Clinical Trauma Professional by Evergreen Certifications. Mrs. Hoy has authored all the What’s Good About Anger? books and expanded workbooks and is a regular pre-conference workshop presenter and track leader for the AACC international conferences. Lynette oversees, authors, and publishes all courses and training curriculum for both the Anger Management Institute and CounselCare Connection, P.C. She is a crisis counselor with the R-3 Continuum, a crisis care network providing counseling and debriefing to various individuals and companies.


Program Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $35 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $70
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

Philadelphia Indemnity Insurance Co. v. Bellin Memorial Hospital

Federal 7th Circuit Court
Philadelphia Indemnity Insurance Co. v. Bellin Memorial Hospital
Civil Court
Insurance Coverage
Citation
Case Number: 
No. 24-1056
Decision Date: 
January 14, 2025
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Affirmed.
Judge: 
BRENNAN

In an insurance coverage dispute where the underlying matter dealt with a breach of contract between a hospital (the insured) and a software company, the insured argued that its insurance company was required to cover damages awarded to it in a trial in the underlying matter by referencing a partial settlement agreement between the insurer and the insured in which the insured argued permitted recovery for claims not covered by the insurance policy. The district court agreed with the insured and the insurer appealed. The Seventh Circuit also agreed and affirmed, finding that the negotiated terms of the settlement agreement should be given their full effect. (JACKSON-AKIWUMI and PRYOR, concurring)

60 Artificial Intelligence Tips in 60 Minutes

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the ISBA Standing Committee on Artificial Intelligence & the Practice of Law
Co-sponsored by ISBA Standing Committee on Legal Technology and ISBA Privacy and Information Security Section


1.0 hour MCLE credit, including 1.0 hour Professional Responsibility MCLE credit in the following category: Professionalism, Civility, Legal Ethics, and Sexual Harassment Prevention credit


Original Program Date: Friday, December 13, 2024
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­January 15, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Join us for this entertaining and educational session focused on the safe and efficient use of artificial intelligence in your practice. Our presenters will give you 60 rapid-fire practical tips and tricks for using several popular artificial intelligence tools and techniques in your daily workflow. Topics include: ChatGPT, privacy and security issues to be aware of, tech support, and more.

Program Speakers:
Aaron W. Brooks, Brooks Law and Consulting, LLC, Naperville
Bryan M. Sims, Sims Law Firm, Ltd., Naperville


Pricing Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $35 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $70
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

Church Mutual Insurance Co. v. Frontier Management, LLC

Federal 7th Circuit Court
Church Mutual Insurance Co. v. Frontier Management, LLC
Civil Court
Appellate Jurisdiction
Citation
Case Number: 
No. 24-1900
Decision Date: 
January 2, 2025
Federal District: 
N.D. Ill., Eastern Div.
Holding: 
Appeal dismissed.
Judge: 
SYKES

In an insurance coverage matter, the court was asked to determine whether the insurer had a duty to defend under a claims made insurance policy where a lawsuit was filed after the expiration of the policy but where the attorney in the underlying lawsuit sent written notice, including an attorney’s lien and a demand for preservation of evidence, prior to the termination date of the insurance policy. The district court entered partial summary judgment in favor of the policyholder, finding that the attorney’s letter was a claim under the policy and that it triggered the insurer’s duty to defend. The district court did not determine whether there was a duty to indemnify and stayed the federal case pending the outcome of the underlying lawsuit in state court. The insurer appealed the stay order and asked the appellate court to reverse the partial summary judgment. During the pendency of the appeal, the parties in the state court reached a settlement and the case was dismissed. The Seventh Circuit dismissed the appeal as moot, explaining that the stay order was the only possible basis for appellate jurisdiction as the partial summary judgment order was not final and appealable and that the stay order “evaporated” with dismissal of the state case. (BRENNAN and ST. EVE, concurring)

Menard, Inc. v. Illinois Farmers Insurance Co.

Menard, Inc. v. Illinois Farmers Insurance Co.
Illinois Appellate Court
Civil Court
Duty to Defend
Citation
Case Number: 
2024 IL App (3d) 230431
Decision Date: 
Monday, December 30, 2024
District: 
3d Dist.
Division/County: 
Will Co.
Holding: 
Affirmed.
Justice: 
BRENNAN

In a declaratory judgment lawsuit regarding insurance coverage, defendant appealed after the circuit court granted summary judgment in favor of the plaintiff regarding the defendant insurance company’s duty to defend in an underlying negligence suit. Defendant, which funded settlement of the underlying lawsuit, reserved the right to clawback the settlement funds if the court found it did not have a duty to defend. On appeal, the insurance company argued it did not have a duty to defend because the plaintiff/insured was not “using” the insured vehicle at the time of the injury. The appellate court affirmed, finding that for the purposes of establishing the duty to defend, the plaintiff was using the insured vehicle and that “use” of the vehicle including loading. (DAVENPORT, concurring and McDADE, dissenting)

Bernacchi v. Illinois Department of Insurance

Bernacchi v. Illinois Department of Insurance
Illinois Appellate Court
Civil Court
Illinois Insurance Code
Citation
Case Number: 
2024 IL App (1st) 231710
Decision Date: 
Friday, December 13, 2024
District: 
1st Dist.
Division/County: 
5th Div./Cook Co.
Holding: 
Affirmed.
Justice: 
MITCHELL

Plaintiff filed a petition for writ of mandamus seeking to compel defendants to investigate and prosecute plaintiff’s claim of improper insurance claims practices against First Chicago Insurance Company under the Illinois Insurance Code and to adopt reasonable rules for implementation of the section of the code that provides the penalties the director can impose if a company engages in improper claims practices. The trial court granted defendants’ motion to dismiss and plaintiff appealed. The appellate court affirmed, finding that the trial court did not err in granting the defendant’s motion to dismiss because the plaintiff did not have a clear right to the relief requested and defendants did not have a clear duty to act and that plaintiff did not have standing to claim that she was injured by the director’s failure to “adopt reasonable rules,” because she did not sufficiently allege an injury associated with this allegation. (MIKVA and ODEN JOHNSON, concurring)

6th Annual Abraham Lincoln's Legal Legacy: Lessons for Today's Lawyers - Democracy, The Constitution, and Lincoln the Lawyer/President - Part 2

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the Illinois State Bar Association
Co-sponsored by the Abraham Lincoln Association


2.75 hours MCLE credit, including 2.75 hours Professional Responsibility MCLE credit in the following category: Professionalism, Civility, Legal Ethics, or Sexual Harassment Prevention credit


Original Program Date: Friday, September 6, 2024
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­January 6, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


Don’t miss ISBA’s 6th Annual Abraham Lincoln’s Legal Legacy seminar as we study Lincoln’s actions as a lawyer and President in facing threats to democracy in America and the United States Constitution. The program takes place in Springfield, which was the center of Lincoln’s law practice and three partnerships, and where Lincoln developed his understanding of the democratic process and his interpretation of the Constitution. It was the venue for many of Lincoln’s significant trials, including the “Peachy” Quinn Harrison murder trial. Join us for this in-depth look at how Lincoln’s view of the Constitution changed over time and evolved into the use of his Presidential War Powers to advance the case of Union and emancipation. Additional topics include:
  • How the 1909 Centennial Celebration of Lincoln’s birth resulted in no minorities attending the festivities and how, at the same time in New York City, concerned citizens formed the NAACP to discuss and address racism and white supremacy in the U.S.;
  • The current ethical issues facing attorneys, including lawyer-client privilege, confidentiality concerns, and limits on lawyers and litigants’ speech during trials;
  • How future lawyers can research Lincoln’s legal career and cases;
  • What current and future lawyers can learn from Lincoln’s legal legacy; and
  • Much more.

Program Coordinators:
J. Steven Beckett, Steve Beckett Law Office LLC, Urbana
Hon. Ronald D. Spears (ret.), Spears Dispute Resolution LLC, Taylorville

Contemporary Ethical Issues*
Join us for a discussion on the ethical issues facing lawyers today, including lawyer-client confidences, confidentiality requirements, restrictions on speech by lawyers and clients during trial, and more.
Melissa A. Smart, Director of Education, Attorney Registration & Disciplinary Commission, Chicago

Looking for Lawyer Lincoln? How Future Lawyers Can Access Lincoln’s Legal Cases, Papers, and Career*
John Lupton, Illinois Supreme Court Historic Preservation Commission, Springfield

Lincoln’s Legacy as Lawyer/President*
This panel presentation discusses what current and future generations of lawyers can learn from Abraham Lincoln as a lawyer and a President.
Moderator: Hon. Ronald D. Spears(ret.), Spears Dispute Resolution LLC, Taylorville
J. Steven Beckett, Steve Beckett Law Office LLC, Urbana
Prof. Brian Dirck, Anderson University, Indiana
Guy C. Fraker, Attorney and Author, Bloomington
John Lupton, Illinois Supreme Court Historic Preservation Commission, Springfield


Program Information:
  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $96.25 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $192.50
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free

6th Annual Abraham Lincoln's Legal Legacy: Lessons for Today's Lawyers - Democracy, The Constitution, and Lincoln the Lawyer/President - Part 1

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!
Presented by the Illinois State Bar Association
Co-sponsored by the Abraham Lincoln Association


3.0 hours MCLE credit, including 2.0 hours Professional Responsibility MCLE credit in the following category: Professionalism, Civility, Legal Ethics, or Sexual Harassment Prevention credit


Original Program Date: Friday, September 6, 2024
Accreditation Expiration Date: January 6, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


 Don’t miss ISBA’s 6th Annual Abraham Lincoln’s Legal Legacy seminar as we study Lincoln’s actions as a lawyer and President in facing threats to democracy in America and the United States Constitution. The program takes place in Springfield, which was the center of Lincoln’s law practice and three partnerships, and where Lincoln developed his understanding of the democratic process and his interpretation of the Constitution. It was the venue for many of Lincoln’s significant trials, including the “Peachy” Quinn Harrison murder trial. Join us for this in-depth look at how Lincoln’s view of the Constitution changed over time and evolved into the use of his Presidential War Powers to advance the case of Union and emancipation. Additional topics include:
  • Lincoln’s representation in the high-profile “Peachy” Quinn Harrison murder trial. (Robert Hitt, a court stenographer at the time, recorded the trial and produced a trial transcript, which is now preserved at the Abraham Lincoln Library and Museum);
  • The 1908 Springfield Race Riot and how its violence and aftermath showed the nation that Lincoln’s struggle for freedom and equality for all citizens was far from a reality;
  • Much more.

Program Coordinators:
J. Steven Beckett, Steve Beckett Law Office LLC, Urbana
Hon. Ronald D. Spears (ret.), Spears Dispute Resolution LLC, Taylorville

Lincoln’s Evolving Views on the Constitution as Lawyer and President*
The program’s opening segment examines Lincoln’s loyalty to the rule of law and commitment to democracy and the rights enshrined in the Declaration of Independence, while at the same tine operating under a Constitution that protected slavery.
Prof. Brian Dirck, Anderson University, Indiana

Lincoln and the “Peachy” Quinn Harrison Murder Trial*
In 1859, a former law clerk of Lincoln’s was murdered, but Lincoln defended the accused, who happened to be the grandson of Reverend Peter Cartwright (who had run against Lincoln for office twice) and the son of a prominent political supporter. Don’t miss this in-depth look at one of Lincoln’s most high profile trials.
Guy C. Fraker, Attorney and Author, Bloomington

1908 Springfield Race Riot
This segment examines the events leading up to racial violence in Lincoln’s Hometown in August 1908, as well as its aftermath.
Kathryn Harris Former Division Manager of Library Services of Abraham Lincoln Presidential Library and Museum and Past-President of Abraham Lincoln Association


Program Information:
  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
  • Fees:
    • ISBA Member Price of $105 is displayed below when you login and program is eligible for Free CLE member benefit.
    • Non-Member Price $210
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students – Free