Landmark American Insurance Company v. Reproductive Genetics Institute Inc.

CourtDistrict Court, N.D. Illinois
DecidedOctober 8, 2025
Docket1:25-cv-01528
StatusUnknown

This text of Landmark American Insurance Company v. Reproductive Genetics Institute Inc. (Landmark American Insurance Company v. Reproductive Genetics Institute Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Landmark American Insurance Company v. Reproductive Genetics Institute Inc., (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

LANDMARK AMERICAN INSURANCE CO.,

Plaintiff, No. 25 CV 1528 v. Judge Manish S. Shah REPRODUCTIVE GENETICS INSTITUTE INC.,

Defendant.

MEMORANDUM OPINION AND ORDER

Plaintiff Landmark American Insurance Company issued a liability coverage policy to defendant Reproductive Genetics Institute, Inc. During the coverage period, Noelia Donamaria filed a class action complaint against RGI alleging various counts of fraud and misrepresentation. Landmark now brings this lawsuit, pursuant to 28 U.S.C. §§ 2201 and 2202, seeking a declaration that it has no duty to defend RGI with respect to Donamaria’s lawsuit. RGI moves to stay this case. For the reasons discussed below, RGI’s motion to stay is denied. I. Legal Standards The Declaratory Judgment Act provides that a district court “may declare the rights and other legal relations of any interested party seeking such declaration.” 28 U.S.C. § 2201(a). “An insured and his insurer have a mutual interest in speedy resolution of the insurer’s duty to supply him a defense against a tort claim that may fall outside the coverage of the insurance policy.” Nationwide Ins. v. Zavalis, 52 F.3d 689, 697 (7th Cir. 1995). For this reason, Illinois law requires an insurer to either defend the insured or seek a declaratory judgment that it has no duty to defend. See Meridian Sec. Ins. Co. v. Sadowski, 441 F.3d 536, 538 (7th Cir. 2006).1 Still, “the power to stay proceedings is incidental to the power inherent in every

court to control the disposition of the causes on its docket with economy of time and effort for itself, for counsel, and for litigants.” Landis v. N. Am. Co., 299 U.S. 248, 254 (1936). “The party requesting a stay bears the burden of showing that the circumstances justify it.” Nken v. Holder, 556 U.S. 418, 434 (2009). In deciding whether a stay is appropriate, courts consider “(i) whether a stay will unduly prejudice or tactically disadvantage the non-moving party, (ii) whether a stay will

simplify the issues in question and streamline the trial, and (iii) whether a stay will reduce the burden of litigation on the parties and on the court.” Pfizer Inc. v. Apotex Inc., 640 F.Supp.2d 1006, 1007 (N.D. Ill. 2009). With reference to the first factor, declaratory complaints regarding insurance coverage are “premature” when they present issues of “ultimate facts” which would otherwise be resolved in the pending litigation. Md. Cas. Co. v. Peppers, 64 Ill. 2d 187, 197 (1976). In other words, the Peppers doctrine states that “it is generally

inappropriate for a court considering a declaratory judgment action to decide issues of ultimate fact that could bind the parties to the underlying litigation.” Allstate Ins.

1 The court has subject-matter jurisdiction over this case because plaintiff is a corporation organized in New Hampshire and with its principal place of business in Georgia, defendant is a corporation organized and with its principal place of business in Illinois, and the amount in controversy exceeds $75,000. [1] ¶¶ 4–6; 28 U.S.C. § 1332(a)(1), (c)(1). Illinois law, the law of the state in which this federal court sits, applies. Fednav Intern. Ltd. v. Continental Ins. Co., 624 F.3d 834, 838 (7th Cir. 2010). The parties agree that Illinois law applies. [14] at 5– 6; [18] at 5. Bracketed numbers refer to entries on the district court docket and page numbers are taken from the CM/ECF header placed at the top of filings. Co. v. Kovar, 363 Ill. App. 3d 493, 501 (2006). That said, Peppers does not preclude declaratory judgment on issues that do not decide an ultimate fact in the underlying case. Twin City Fire Ins. Co. v. Law Off. of John S. Xydakis, P.C., 407 F.Supp.3d 771,

778–79 (N.D. Ill. 2019). II. Background A. The Underlying Lawsuit In October 2024, Noelia Donamaria filed a lawsuit against RGI asserting that (1) RGI advertises, markets, and sells preimplantation genetic testing for aneuploidy (PGT-A) testing; (2) RGI sells that testing in connection with the IVF process to

screen embryos for abnormalities; and (3) Donamaria and other purported class members purchased the testing from RGI and relied on its representations through its advertising and marketing. [1] ¶¶ 9–10. The underlying lawsuit alleges causes of actions for violations of Illinois’s Consumer Fraud and Deceptive Business Practices Act, 815 Ill. Comp. Stat. 505/2 and Uniform Deceptive Trade Practices Act, 815 Ill. Comp. Stat. 510/2, breach of the implied warranty of merchantability, breach of the implied warranty of usability,

fraud, fraud by concealment, unjust enrichment, and breach of express warranty. [1] ¶ 11. These counts are based on claims that RGI engaged in false and deceptive advertising and failure to fully disclose the accuracy of its PGT-A testing. [1] ¶ 11. B. The Landmark Policy The relevant Landmark insurance policy covers RGI as an “Embryo Storage Lab” from December 31, 2023, to December 31, 2024. [1-2] at 3. The policy includes two separate coverages: Commercial General Liability coverage and Medical Professional Liability coverage. [1-2] at 6. The policy also includes an endorsement carving out claims “based upon or arising directly, or indirectly, out of any actual or

alleged violation of any federal, state or local consumer protection law(s), statute, ordinance or regulation.” [1-2] at 71. The general liability policy provides that Landmark will pay those sums that the insured becomes legally obligated to pay as damages because of “bodily injury,” “property damage,” or “personal and advertising injury” to which the insurance applies. [1-2] at 7, 14. The medical professional liability policy provides that

Landmark will pay damages “arising out of a negligent act, error, or omission … in the rendering of or failure to render professional services.” [1-2] at 29. The policy’s declarations define RGI’s professional services as an “embryo storage lab.” [1-2] at 58. The medical liability coverage does not apply to any claim “based upon or arising out of … dishonest, fraudulent, criminal, malicious, or intentional acts, errors or omissions committed by or at the direction of any Insured.” [1-2] at 32. III. Analysis

RGI moves to stay on the grounds that this court, in considering the declaratory judgment action, will be required to determine “ultimate facts” in the underlying case. RGI argues that “Landmark’s Complaint calls for a determination of whether RGI’s conduct was intentional or negligent as part of any determination regarding coverage.” [14] at 6. In response, Landmark argues that “the eight corners of the Landmark Policy and the Underlying Lawsuit” are sufficient to find that declaratory relief would not comment on any ultimate question in the underlying lawsuit. [18] at 6. I agree. In Peppers, an insured defendant was sued in a personal injury action for

intentional, negligent, and willful and wanton conduct. 64 Ill. 2d at 190–95.

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Related

Landis v. North American Co.
299 U.S. 248 (Supreme Court, 1936)
Nken v. Holder
556 U.S. 418 (Supreme Court, 2009)
Fednav International Ltd. v. Continental Insurance
624 F.3d 834 (Seventh Circuit, 2010)
Meridian Security Insurance Co. v. David L. Sadowski
441 F.3d 536 (Seventh Circuit, 2006)
Pfizer Inc. v. Apotex Inc.
640 F. Supp. 2d 1006 (N.D. Illinois, 2009)
Maryland Casualty Co. v. Peppers
355 N.E.2d 24 (Illinois Supreme Court, 1976)
Allstate Insurance v. Kovar
842 N.E.2d 1268 (Appellate Court of Illinois, 2006)
Rebecca Zander v. Samuel Orlich, Jr.
907 F.3d 956 (Seventh Circuit, 2018)

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Landmark American Insurance Company v. Reproductive Genetics Institute Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/landmark-american-insurance-company-v-reproductive-genetics-institute-inc-ilnd-2025.