Madison Mutual Insurance Co. v. O'Brien

2024 IL App (4th) 231370-U
CourtAppellate Court of Illinois
DecidedOctober 18, 2024
Docket4-23-1370
StatusUnpublished

This text of 2024 IL App (4th) 231370-U (Madison Mutual Insurance Co. v. O'Brien) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Madison Mutual Insurance Co. v. O'Brien, 2024 IL App (4th) 231370-U (Ill. Ct. App. 2024).

Opinion

2024 IL App (4th) 231370-U FILED NOTICE This Order was filed under October 18, 2024 Supreme Court Rule 23 and is NO. 4-23-1370 Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed IN THE APPELLATE COURT Court, IL under Rule 23(e)(1). OF ILLINOIS

FOURTH DISTRICT

MADISON MUTUAL INSURANCE COMPANY, ) Appeal from the Plaintiff-Appellant, ) Circuit Court of v. ) Tazewell County JEAN O’BRIEN, Independent Administrator of the ) No. 20MR231 Estate of Carol Weidman, Deceased; CASSANDRA ) WEIDMAN, a Minor by Her Motion and Next Friend; ) KIMBERLY WEIDMAN; SUSAN KING; MISTY ) Honorable YOUNG; and CAMERON WEIDMAN, ) Paul E. Bauer, Defendants-Appellees. ) Judge Presiding.

JUSTICE ZENOFF delivered the judgment of the court. Justices Harris and Knecht concurred in the judgment.

ORDER

¶1 Held: The appellate court reversed the trial court’s grant of summary judgment to the defendants where a genuine issue of material fact existed as to whether the insured made a material misrepresentation in her application for insurance. The appellate court affirmed the trial court’s dismissal of counts III and IV of the insurer’s second amended complaint with prejudice.

¶2 After a pit bull owned by Carol Weidman (now deceased) attacked Susan King,

Madison Mutual Insurance Company (Madison Mutual) rescinded a homeowners insurance policy

it had previously issued to Carol. Madison Mutual then sought a declaration that rescission of the

policy was proper, asserting that it was void because Carol falsely claimed in her application for

insurance that she owned no dogs. Madison Mutual and defendants—Jean O’Brien (as the

administrator of Carol’s estate (Estate)), Cassandra Weidman, Kimberly Weidman, Susan King,

and Misty Young—filed cross-motions for summary judgment. The trial court denied Madison Mutual’s motion and granted summary judgment in favor of defendants on the basis that no

evidence established that Carol made a misrepresentation about her ownership of a pit bull. After

Madison Mutual filed an amended complaint raising several policy defenses, the court granted

defendants’ motions to dismiss two of those defenses. Madison Mutual now appeals, arguing that

summary judgment should not have been granted in favor of defendants or, alternatively, the court

erred in dismissing two of the policy defense claims. We affirm in part, reverse in part, and remand.

¶3 I. BACKGROUND

¶4 The following facts are taken from the record, including depositions and documents

attached to the cross-motions for summary judgment. We will supplement the facts as necessary

in our analysis.

¶5 Prior to July 2019, Carol lived in her home with her grandson, Cameron Weidman,

and his pit bull, “Cash.” In July 2019, Cameron left for military boot camp and left Cash with

Carol, who fed and cared for the dog in her home.

¶6 In November 2019, Carol and her daughter, Kimberly, spoke over the phone with

Patty Ledbetter, an employee of Ledbetter Insurance Agency, Inc. (Ledbetter Insurance Agency),

and requested a quote for a homeowners insurance policy.

¶7 At Patty’s deposition, she explained that to prepare a quote, Ledbetter Insurance

Agency used worksheets containing questions tailored to the requested policy type. As part of her

job duties, she would “read through verbatim the questions on the worksheet [to the customer] and

fill out the answers accordingly.” Based upon the given answers, she would prepare a quote, which

would be reviewed by Brian Ledbetter, the owner of Ledbetter Insurance Agency. Once approved

by Brian, she would provide the quote to the customer. If the customer was satisfied with it, Patty

-2- would prepare an application using the information the customer provided, have the customer sign

the completed application, and submit it to an insurance company.

¶8 One of the insurance companies that Ledbetter Insurance Agency worked with was

Madison Mutual. Pursuant to an “Agency Contract,” Madison Mutual granted Ledbetter Insurance

Agency, as “the Agent,” “full power and authority to receive and accept applications for insurance

covering such classes of risks as [Madison Mutual] may from time to time authorize to be insured,

and at the discretion of [Madison Mutual] to deliver policies and collect funds for [Madison

Mutual].” The Agency Contract further provided that “[t]he Agent may solicit such applications

by such manner, time, and place as is generally considered proper, and all expenses in connection

with solicitations shall be the Agent’s.”

¶9 According to Patty, to obtain a homeowners policy quote for Carol, she asked Carol

questions from the appropriate worksheet and filled out the answers herself. One of the lines on

the questionnaire read:

“ANY DOGS IN HOME Y/N KIND________________.”

On the completed worksheet, “N” was circled, and the line after “KIND” was blank. Patty could

“not remember the conversation” and could not “specifically remember” asking Carol whether

there were any dogs in her home, as she “do[es] 100 of these” questionnaires. However, she stated

there had never been a time when she did not ask the questions on the worksheet, as “the procedure

is to read through the questions.” She affirmed that she went through each question in every section

of the questionnaire. Thus, Patty testified that the conversation would have entailed her asking

whether there were any dogs in the home, as that question was on the worksheet. Patty testified

that, because she circled “N” for the question of whether there were any dogs in the home, she did

not discuss with Carol whether she had any specific breed of dog. She explained that if a person

-3- told her there was a dog in the home, she would have proceeded to the “next question, what kind

of dog is it,” to “make sure it wasn’t on the no coverage list.” Patty did not show Carol the

completed worksheet.

¶ 10 After providing a quote to Carol, Patty prepared an application for a Madison

Mutual homeowners insurance policy using the information in the worksheet. The application was

five pages long. The heading on the third page read, “Underwriting Information.” The first

question under that heading read, “Do you have a Chow, Pit Bull, Doberman, Rottweiler, Mastiff,

Wolf Hybrid, Presa Canarios, Akita, or Staffordshire Terrier dog?” The answer next to that

question was “No.” Madison Mutual included this question because at that time, it would not allow

coverage if any of those breeds were in the applicant’s home.

¶ 11 On November 15, 2019, Patty presented the prepared application to Carol for her

signature. According to Patty, she gave Carol all the pages of the application except for the

“Underwriting Information” page containing the question about dog breeds. Above the signature

lines on the last page were the following paragraphs:

“I have read this application all [sic] information contained herein is correct.

If this application contains a material misrepresentation, I fully understand that the

Company may rescind this policy as of the effective date of the application and

declare this policy void from its inception and/or cancel any and all coverage. It is

further understood that this application is a part of the policy when issued and that

[it] is intended that the Company shall rely on the contents of this application in

issuing any policy of insurance or renewal.

***

-4- I understand that none of the coverages noted on this application is [sic] in

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Bluebook (online)
2024 IL App (4th) 231370-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/madison-mutual-insurance-co-v-obrien-illappct-2024.