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Insurance Coverage

Insurance Coverage

Your Trusted Insurance Coverage Lawyers in Illinois

Carlson Bier Associates is your premier choice for expert legal counsel in insurance coverage matters throughout the state of Illinois. Our team, led by attorneys Jeff Bier, David Jenkins, Richard Craig, and supported by of-counsel George Leynaud, specializes in navigating the complexities of insurance policies and ensuring our clients’ coverage needs are met.

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Jeff is an experienced attorney with in-depth knowledge of insurance coverage and a member of the IL State Bar Association's insurance section. He excels in protecting insurer resources and is dedicated to defending the rights of policyholders.
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Jeff Bier

Founding Partner
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David's expertise lies in insurance policy interpretation and analysis. His meticulous approach ensures that clients receive the coverage they are entitled to. David has extensive appellate experience.
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David Jenkins

Of Counsel
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Rich is a tenacious advocate and a seasoned trial lawyer. Rich’s expertise in civil procedure and excellent writing skills gives Carlson Bier a decided advantage in litigation.
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Richard Craig

Of Counsel
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George's decades of experience as a trial lawyer and personal injury attorney lends invaluable perspective to Carlson Bier insurance coverage practice. His involvement in the Illinois State Bar Association insurance and torts sections keeps us at the forefront of insurance law.
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George Leynaud

Of Counsel
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Understanding the Importance of Insurance Coverage

In today’s unpredictable world, insurance coverage stands as a protective shield against unforeseen adversities. Whether it’s a sudden accident, property damage, or any other unexpected event, having the right insurance coverage can make a significant difference in how one navigates such challenges. However, understanding and interpreting insurance policies can be a daunting task for many. This is where the expertise of insurance coverage lawyers becomes invaluable.

Our Expertise

With a strong focus on insurance coverage, our firm brings a wealth of knowledge and experience to the table. We specialize in personal insurance lines, including automobile and homeowner policies, as well as small business policies such as commercial general liability policies and farm policies. Our dedication to understanding insurance law nuances ensures we provide you with the best representation for your coverage concerns.

Your peace of mind through comprehensive insurance coverage is our priority, and we are committed to helping you achieve it.

Our Practice Area

We are proud to serve clients across Illinois, offering tailored legal guidance in insurance coverage matters. Our expertise extends to representing clients in circuit courts and the appellate court system, ensuring that policyholders receive comprehensive coverage assistance.

Why Choose Us?

When you choose Carlson Bier Associates for your insurance coverage needs, you can expect:

Focused expertise in insurance policy analysis and interpretation.
A team of passionate professionals dedicated to securing your coverage.
Customized strategies tailored to your specific insurance concerns.
A proven track record of successfully securing coverage benefits
In-depth knowledge of Illinois insurance regulations.​
Accessible, open communication with our attorneys.​
Key appellate victories.​

Staying Ahead of the Curve

Insurance laws and regulations are constantly evolving. To ensure our clients receive the best advice and representation, our team stays updated with the latest developments in the field. We participate in continuous legal education, attend industry seminars, and engage in peer discussions. This proactive approach ensures that we are always a step ahead, ready to tackle any insurance-related challenge that comes our way.

Building Trust, One Client at a Time

Trust is the cornerstone of any attorney-client relationship. At Carlson Bier Associates, we prioritize building and maintaining this trust. From the moment you walk through our doors, you’ll experience a level of dedication and commitment that sets us apart. Our insurance coverage lawyers take the time to understand your unique situation, offering tailored solutions that align with your best interests.

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Notable Appellate Wins

Moruzzi v. CCC Servs., Inc., 2020 IL App (2d) 190411, 171 N.E.3d 61
Background: Insured motorist filed action against insurer for declaratory judgment seeking construction of automobile insurance policy issued to insured and that was in effect when insured was injured by an underinsured driver. The Circuit Court, DuPage County, Bonnie M. Wheaton, J., granted the insurer's motions for summary judgment. Insured appealed.Holdings: The Appellate Court, Zenoff, J., held that:1 medical payments reduction clause in automobile insurance policy conflicted with underinsured motorist provisions so as to render reduction clause ambiguous, and thus medical payment benefits were deductible from insured's damages;2 law firm representing insured did not create common fund or common funds when it reached settlement with underinsured motorist, and thus law firm was not entitled to recover fees under common-fund doctrine; and3 collateral estoppel did not bar automobile insurers from litigating whether common-fund doctrine applied in insured motorist's declaratory judgment action.Affirmed in part and reversed in part.
Maier v. CC Servs., Inc., 2019 IL App (3d) 170640, 132 N.E.3d 795
Background: After insured, who was injured in automobile collision with another driver, recovered full liability limits of driver's policy, she filed amended complaint for declaratory judgment against her own automobile insurer, alleging that insurer breached contractual duty to pay for insured's damages in accordance with uninsured/underinsured motorist (UIM) coverage in insured's policy and that insurer acted in bad faith in denying insured such coverage. The Circuit Court, La Salle County, Troy D. Holland, J., granted the insurer's motion to dismiss claims as time-barred. Insured appealed.The Appellate Court ruled that neither the insurer nor the insured could add amended policy provisions to the court record. It was decided that the policy's requirement for a written arbitration demand applied to both uninsured and underinsured motorist claims. The court found that a letter from the insured's attorney to the insurer wasn't a valid arbitration demand nor a proof of loss to toll the statute of limitations. Finally, the insurer was permitted to use the defense based on the two-year statute of limitations period. The court's decision was affirmed.
Econ. Premier Assurance Co. v. Country Mut. Ins. Co., 2021 IL App (1st) 192364-U
Holding: The circuit court's order that granted defendant's motion for summary judgment and denied plaintiff's motion for partial summary judgment was proper where defendant had no duty to indemnify its insured with respect to the underlying complaint and therefore plaintiff was not entitled to recover against defendant on its subrogation or unjust enrichment claims; affirmed.
Country Preferred Ins. Co. v. Westerheide, 2023 IL App (5th) 220343-U
Holding: The court affirmed judgment of the circuit court granting summary judgment in favor of the plaintiff where the defendant failed to make a written demand for arbitration within two years from the date of the accident as required by the underinsured provisions of the defendant's automotive insurance policy.
Country Mut. Ins. Co. v. Olsak, 2022 IL App (1st) 200695, 216 N.E.3d 291
In a complex legal case, an insurer sought to avoid defending or indemnifying a hockey player under a policy issued to the player's stepfather after the player was sued for assaulting his coach. The initial Circuit Court ruling favored the insurer, but the Appellate Court reversed this decision, leading to a protracted legal battle. Ultimately, the Appellate Court determined the insurer was liable only up to the $3 million policy limit and found the insurer's four-year delay in seeking a declaratory judgment to be reasonable. This case highlights important aspects of insurance litigation and policy limit liabilities.
Country Mut. Ins. Co. v. Durkin Elec. Co., Inc., 2022 IL App (1st) 210293-U, appeal denied, 199 N.E.3d 1187 (Ill. 2022)
Holding: The circuit court's order that denied plaintiff's motion for partial summary judgment and found that defendant was an additional insured under the policy was proper. The circuit court's order that denied defendant's motion for summary judgment and found that plaintiff did not have a duty to defend or indemnify defendant under the policy was proper; affirmed.
Country Preferred Ins. Co. v. Groen, 2017 IL App (4th) 160028, 69 N.E.3d 911
Background: Uninsured motorist (UM) carrier brought action against insured for declaratory judgment that it owed no benefits since workers' compensation received by insured exceeded policy limits. The Circuit Court, Sangamon County, Chris Perrin, J., entered summary judgment in favor of the carrier. Insured appealed.Holdings: The Appellate Court, Harris, J., held that:1 employer's medical payments entitled carrier to setoff, and2 setoff clauses were enforceable.Affirmed.
Country Mut. Ins. Co. v. Frobish, 2021 IL App (3d) 190473-U
Holding: Allegations in the underlying complaint that a township employee caused property damage by excavating and digging out a ditch failed to impose a duty to defend under township employee's individual farm insurance policy.
Country Mut. Ins. Co. v. Jones, 2018 IL App (1st) 173154-U
Holding: The judgment of the circuit court of Cook County is affirmed; plaintiff is entitled to summary judgment on its claim for a declaratory judgment that it has no duty to defend or indemnify its insured against the underlying complaint because the loss claimed in the underlying complaint is subject to an exclusion. The court held that it would also enter judgment for plaintiff because the underlying complaint does not allege an “occurrence” causing bodily injury within the meaning of the policy.
Country Mut. Ins. Co. v. Schmitt, 2021 IL App (5th) 190173-U
Holding: The appellate court reversed and remanded the judgment of the circuit court where plaintiff had no duty to defend its insured and thus was not stopped from raising policy defenses to coverage for the underlying tort action contained in the amended declaratory action.
Country Mut. Ins. Co. v. Livorsi Marine, Inc., 222 Ill. 2d 303, 856 N.E.2d 338 (2006) (the late Keith Carlson)
Liability insurer brought action against insureds for a declaratory judgment based on failure to provide timely notice of lawsuits against them. The Circuit Court, Cook County, Stephen A. Schiller, J., entered judgment for the insurer. Insureds appealed. The Appellate Court, Wolfson, J., 358 Ill.App.3d 880, 295 Ill.Dec. 665, 833 N.E.2d 871, affirmed. Leave to appeal was granted.Holdings: The Supreme Court, Garman, J., held that:1 if the insurer did not receive reasonable notice of an occurrence or a lawsuit, the policyholder may not recover under the policy, regardless of whether the lack of reasonable notice prejudiced the insurer, overruling Rice v. AAA Aerostar, Inc., 294 Ill.App.3d 801, 229 Ill.Dec. 20, 690 N.E.2d 1067, and Cincinnati Insurance Co. v. Baur's Opera House, Inc., 296 Ill.App.3d 1011, 230 Ill.Dec. 624, 694 N.E.2d 593, and2 insured did not need to prove that it was prejudiced by delayed notice of lawsuits.Affirmed.
Country Mutual Insurance Company v. Gary Gang Xu, Xingjian Sun, Xing Zhao, and AO Wang, 2024 IL App (5th) 220287-U
The trial court did not err in granting summary judgment in favor of the insurer on its complaint for a declaratory judgment that it had no duty to defend or indemnify its insured because the acts alleged in the underlying complaint did not fall within or potentially within coverage or were subject to a policy exclusion, and the trial court’s judgment is affirmed.
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If you require assistance with insurance coverage matters or have questions about your insurance policy, Carlson Bier Associates is here to provide expert guidance. Reach out to us today to schedule a consultation, and let our experienced legal team ensure that you have the coverage you need.

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