Scott v. American Alliance Casualty Co.

2024 IL App (4th) 231305
CourtAppellate Court of Illinois
DecidedJune 21, 2024
Docket4-23-1305
StatusPublished
Cited by3 cases

This text of 2024 IL App (4th) 231305 (Scott v. American Alliance Casualty Co.) 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
Scott v. American Alliance Casualty Co., 2024 IL App (4th) 231305 (Ill. Ct. App. 2024).

Opinion

2024 IL App (4th) 231305 FILED NO. 4-23-1305 June 21, 2024 Carla Bender IN THE APPELLATE COURT 4 th District Appellate Court, IL OF ILLINOIS

FOURTH DISTRICT

HERMAN SCOTT and ARIANNE JONES, ) Appeal from the Plaintiffs-Appellees, ) Circuit Court of v. ) Peoria County AMERICAN ALLIANCE CASUALTY COMPANY and ) No. 22LA247 TIARA LLOYD, ) Defendants ) Honorable (American Alliance Casualty Company, Defendant- ) Stewart James Umholtz, Appellant). ) Judge Presiding.

JUSTICE HARRIS delivered the judgment of the court, with opinion. Justices Doherty and DeArmond concurred in the judgment and opinion.

OPINION

¶1 Plaintiffs, Herman Scott and Arianne Jones, brought the present action against

defendants, American Alliance Casualty Company (American Alliance) and Tiara Lloyd,

alleging claims for violating the Consumer Fraud and Deceptive Business Practices Act (Act)

(815 ILCS 505/1 et seq. (West 2020)), bad faith pursuant to section 155 of the Illinois Insurance

Code (215 ILCS 5/155 (West 2020)), declaratory judgment, and promissory estoppel. American

Alliance filed a motion to dismiss plaintiffs’ complaint, which the trial court denied. It then

requested the court find that the order involved a disputed question of law and certify the

question under Illinois Supreme Court Rule 308(a) (eff. Oct. 1, 2019).

¶2 The trial court certified the following question pursuant to Rule 308(a): “Pursuant to [section 143a-2(4) of the Insurance Code (215 ILCS 5/143a-2(4)

(West 2020))], is underinsured motorist coverage automatically required to be

included in a policy insuring liability for bodily injury where the policy provides

uninsured motorist coverage at the minimum limits required by [section 7-203 of

the Illinois Vehicle Code (625 ILCS 5/7-203 (West 2020))]?”

¶3 We answer the certified question in the negative.

¶4 I. BACKGROUND

¶5 On November 23, 2022, plaintiffs filed their initial complaint against defendants.

On March 29, 2023, plaintiffs filed their first amended complaint, which set forth six counts: one

count of violating the Act, two counts of bad faith pursuant to section 155 of the Insurance Code

(215 ILCS 5/155 (West 2020)), two counts seeking a declaratory judgment, and one count of

promissory estoppel.

¶6 The first amended complaint alleged that American Alliance issued an automobile

insurance policy to Scott providing the statutory minimum bodily injury liability coverage of

$25,000 per person and $50,000 per accident. The policy also provided uninsured motorist

coverage in the amount of $25,000 per person and $50,000 per accident. While the policy was in

effect, plaintiffs were injured in a multi-vehicle crash for which Lloyd was at fault. Scott was

driving the vehicle at the time of the crash, and Jones was his passenger. Eleven people were

injured as a result of the crash, and Lloyd had an insurance policy that provided aggregate

liability coverage of $50,000 to be split among the injured parties. Though plaintiffs incurred

medical expenses exceeding $40,000 due to their injuries from the crash, Scott received only

$4060.24 from Lloyd’s policy, and Jones received only $8410.54 as a result of the split.

American Alliance initially confirmed that Scott’s policy included underinsured motorist

-2- coverage. However, it later reversed its position and refused to pay plaintiffs for their

underinsured motorist claims related to the crash, claiming Scott’s policy did not include

underinsured motorist coverage.

¶7 The first amended complaint alleged Scott’s policy was vague and ambiguous

regarding underinsured motorist coverage. It also alleged that selling an automobile insurance

policy without underinsured motorist coverage with minimum limits of $25,000 per person and

$50,000 per accident violated section 143a-2(4) of the Insurance Code (215 ILCS 5/143a-2(4)

(West 2020)) and section 7-203 of the Vehicle Code (625 ILCS 5/7-203 (West 2020)). The first

amended complaint asserted that selling a policy without underinsured motorist coverage, as

American Alliance purported to do, was a deceptive and illegal act in violation of the Act such

that Scott was entitled to compensatory and punitive damages under the Act.

¶8 The first amended complaint also alleged that plaintiffs were entitled to damages

under section 155 of the Insurance Code (215 ILCS 5/155 (West 2020)) because American

Alliance acted in bad faith in refusing to pay plaintiffs’ underinsured motorist claims based on its

position that Scott’s policy did not provide underinsured motorist coverage, which plaintiffs

claimed was legally required to be included in the policy. Plaintiffs also sought a declaratory

judgment determining that underinsured motorist coverage existed under Scott’s policy at the

statutory minimum limits or that the court order the policy to be reformed to include

underinsured motorist coverage at the statutory minimum limits pursuant to section 143a-2(4) of

the Insurance Code (id. § 143a-2(4)) and section 7-203 of the Vehicle Code (625 ILCS 5/7-203

(West 2020)). The first amended complaint also set forth a claim of promissory estoppel based

on American Alliance’s alleged prior representation to Scott that his policy contained

-3- ¶9 On March 30, 2023, American Alliance filed a motion to dismiss plaintiffs’

complaint, pursuant to section 2-619.1 of the Code of Civil Procedure (735 ILCS 5/2-619.1

(West 2022)), which the trial court subsequently construed as a motion to dismiss the first

amended complaint. The motion to dismiss asserted several bases for dismissal. Relevant to this

appeal, the motion asserted that the declaratory judgment counts should be dismissed, pursuant

to section 2-615 of the Code of Civil Procedure (id. § 2-615), because Illinois law did not require

that Scott’s policy include underinsured motorist coverage. Specifically, the motion to dismiss

claimed that section 143a-2(4) of the Insurance Code (215 ILCS 5/143a-2(4) (West 2020))

mandated underinsured motorist coverage only where a policy’s uninsured motorist coverage

exceeded the statutory minimum amount of liability coverage, and Scott’s policy contained

uninsured motorist coverage at the statutory minimum limits.

¶ 10 On July 12, 2023, the trial court held a hearing on American Alliance’s motion to

dismiss. The court denied the motion, finding, inter alia, that it was not clear whether

underinsured motorist coverage was required by law to be included in Scott’s policy.

¶ 11 On September 27, 2023, American Alliance filed in the trial court a “Motion for

Leave to Appeal,” in which it requested that the court certify a question of law pursuant to Rule

308(a).

¶ 12 On October 26, 2023, the trial court granted American Alliance’s motion, finding

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2024 IL App (4th) 231305, Counsel Stack Legal Research, https://law.counselstack.com/opinion/scott-v-american-alliance-casualty-co-illappct-2024.