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About Carlson Bier Associates

When it comes to matters of personal injury, Carlson Bier Attorney Group has consistently remained unmatched in offering expert legal guidance and representation. Our keen understanding of Illinois law provides us with a robust foundation upon which we can advocate fiercely for our clients’ rights whilst displaying utmost professional acumen. Personal injuries – be they slips, workplace incidents or car accidents – necessitate an immediate response as well as a potent defense; this is precisely where Carson Bier excels. Based on the facts and relevant legal provisions rather than case gimmicks, we craft unique strategies designed to ensure maximum compensation for suffering endured by victims to whom we offer our services. With years of experience dealing specifically with personal injury cases, Carlson Bier prepares you not just for the courtroom but also assists in comprehending complex litigation processes ensuring clarity at every step. All these factors continually solidify our status as your preeminent selection when pursuing justice against those responsible for inflicting unwarranted harm through their negligence or deceit.

Meet Our Attorneys
About Carlson Bier

Personal Injury Lawyers in Erie Illinois

Welcome to Carlson Bier, your dedicated personal injury attorneys based right here in Illinois. We value your time and trust, which is why we endeavor to provide you with comprehensive educational content about Personal Injury Law and its intricacies. If you or someone else you know has been a victim of an accident resulting in physical harm, emotional distress or any other life-altering outcomes, understanding the basics of personal injury law can be crucial towards taking the first step in seeking justice and rightful compensation.

Personal Injury Law primarily pertains to legal disputes that occur when one party suffers harm from an accident that another party could potentially be legally accountable for. Such cases typically emerge after an event where negligence played a key role. Accidents such as car crashes, workplace injuries, medical malpractice are just a few examples where this law applies. Delving deeper into the finer principles of this sphere will assure equitable judgment under respective circumstances.

– Negligence concept: This refers to any accidental actions or repercussions arising out of negligence on part of either individuals’ responsibilities or entities’ prevailing guidelines.

– Liability assessment: The degree to which each party involved is liable significantly influences the case’s final resolution.

– Damages estimation: Besides physical injuries and property damage restitution, many other subtle aspects come into play that influence overall damages estimation like mental anguish,, loss of companionshipmental anguish and others.

Our services at Carlson Bier cover all these potential issues through effective representation that gives victims a powerful voice against aggravated parties including reckless drivers, negligent health care providers, irresponsible product manufacturers among others.

Navigating through personal injury proceedings requires not just good counsel but also contextual knowledge application suited best for specific scenarios while diligently adhering to state-specific laws. Here at Carlson Bier’s Illinois office; we understand how pivotal it is for our clients who’ve entrusted their situations onto us by anticipating tactful measures coupled with planned strategies mastering extensive procedural complexities toward effectively ensuring rightful settlements.

Over the years, our seasoned team of attorneys has handled a diverse array of personal injury cases applying distinct principles and acumen bearing Illinois legislation in mind. Our commitment to responsibility and transparency sets us apart as we consciously serve you without resorting to false advertising or misleading promises regarding unrealistic high compensation figures. Instead, at Carlson Bier, we firmly believe in molding truthfulness with precision right from consultation phase till judgement execution.

Making informed decisions often involves a multitude of aspects, some less known but equally crucial for anyone seeking justice via personal injury law route. Therefore, if you wish to understand more about your eligibility according to specific case grounds or any further query concerning legal processes; allow our expert team at Carlson Bier to assist through elaborative discourse bridging gaps between prevailing misconceptions and actual legal proceedings related knowledge.

127 South St., Illinois is not just an address location but signifies a beacon towards achieving rightful claim settlements under personal injuries circumstances through Carlson Bier’s tireless devotion toward each client’s cause irrespective of its complexity degree.

And even though the quest for justice might seem daunting alongside managing physical recovery parallelly; remember that every situation holds unique potentialities striving for personalized resolutions meeting compensational expectations fairly while ensuring compliance with Illinois jurisdictional boundaries entirely throughout this process fostering complete legal integrity.

Thanks again for giving us your genuine consideration towards understanding Personal Injury Law’s varied facets via this educational content page brought forward by your fellow Illinois-based advocates here at Carlson Bier: lawyers who believe in merging compassion with lawyering skills making justice pursuit more humane effectively than ever before.

Finally, motivated toward unearthing additional insights regarding your case? Click on the button below empowering realistic estimations revealing true value deserving compensation associated with individual claim circumstances distinctly brought alive by comprehensive evaluation standards practiced extensively here at Carlson Bier across numerous past representations successfully turning tables favorably representing many like yourself predominantly within our beloved state – Illinois where judicial wisdom meets passionate advocacy instigators exceptionally through Carlson Bier’s astute offerings impeccably. Delve deeper into your case’s potential value now by clicking below.

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Notable Illinois 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.
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Areas of Practice in Erie

Pedal Cycle Accidents

Focused on legal services for persons injured in bicycle accidents due to other parties' indifference or dangerous conditions.

Thermal Wounds

Giving expert legal support for sufferers of severe burn injuries caused by accidents or indifference.

Physician Incompetence

Delivering expert legal advice for clients affected by healthcare malpractice, including misdiagnosis.

Goods Responsibility

Dealing with cases involving faulty products, providing expert legal help to customers affected by faulty goods.

Senior Abuse

Protecting the rights of the elderly who have been subjected to mistreatment in elderly care environments, ensuring fairness.

Tumble & Fall Injuries

Skilled in handling stumble accident cases, providing legal support to individuals seeking recovery for their suffering.

Newborn Traumas

Delivering legal support for relatives affected by medical malpractice resulting in childbirth injuries.

Vehicle Collisions

Crashes: Committed to assisting individuals of car accidents gain fair payout for harms and destruction.

Motorbike Accidents

Expert in providing legal assistance for motorcyclists involved in bike accidents, ensuring adequate recompense for traumas.

Truck Collision

Ensuring adept legal services for persons involved in lorry accidents, focusing on securing fair settlement for injuries.

Construction Accidents

Concentrated on advocating for workmen or bystanders injured in construction site accidents due to negligence or carelessness.

Cerebral Harms

Dedicated to delivering expert legal assistance for victims suffering from cognitive injuries due to accidents.

Canine Attack Wounds

Expertise in addressing cases for persons who have suffered damages from dog bites or wildlife encounters.

Jogger Crashes

Expert in legal representation for walkers involved in accidents, providing expert advice for recovering restitution.

Wrongful Loss

Working for relatives affected by a wrongful death, extending sensitive and skilled legal guidance to ensure restitution.

Neural Damage

Dedicated to defending individuals with vertebral damage, offering specialized legal assistance to secure justice.

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