Keith Carlson – In Memorium
One of the most important cases Keith litigated was County Mutual Ins. Co. v. Livorsi Marine, Inc. (222 Ill.2d 303 856 N.E.2d 338) at the Illinois Supreme Court. This case established in Illinois that an insurer does not have to be prejudiced by late notice in order to cite late notice as a coverage defense. This is a minority position among the states and is one of the 50 most cited cases in insurance coverage law in the United States.
Wayne State University Law School
Juris Doctor, Cum Laude.1984
Oakland State University
B.S. Political Science 1981
Supreme Court Cases
- Country Mutual Ins. Co v. Livorsi Marine, Inc. – 222 III.2d 303 856 N.E.2d 338 – Supreme Court of Illinois Insurance – Liability. Insurer that received delayed notice of lawsuits did not need to prove that it was prejudiced by delay.
- Greszcak v. Illinois Farmers Ins. Co. – 168 II1.2d 216 659 N.E.2d 952 – Supreme Court of Illinois Automobile Insurance. Unambiguous antistacking clauses did not violate public policy and were to be enforced.
- Country Preferred Insurance Co. v. Whitehead – 2012IL 113365 979 N.E.2d 35 – Supreme Court of Illinois. Insurance Automobile. Two-vear contractually limitation on claim arbitration for uninsured – motorist claim did not violate public policy.
Appellate Court Cases
- Busch v. Country Financial Insurance Co. – 2018 IL App (5th) 140621 95 N.E.3d 40 – Appellate Court of Illinois, Fifth District Insurance Automobile. Antistacking clause limiting liability if insurer issued multiple policies precluded recovery of uninsured benefits under two polices.
- Maier v. CC Services, Inc – 2019 IL APP (3d) 170640 132 N.E.3d 795 Appellate Court of Illinois, Third District Insurance – Automobile. Automobile insurer was not stopped from raising defense based on two-year limitations period in action brought by insurer.
- Country Preferred Insurance Company v. Groen – 2017 IL App (4th) 160028 69 N.E.3d 911 – Appellate Court of Illinois, Fourth District Insurance – Automobile. Employer’s medical payments under workers Compensation law entitled carrier to setoff.
- These are representative of the 15+ I have argued at the appellate level