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About Carlson Bier Associates

In the realm of personal injury law, Carlson Bier stands out as a paragon of dedication and expertise. Our pursuit for justice for our clients, irrespective of their location in Illinois, has firmly established Carlson Bier as the go-to firm for those seeking representation in personal injury cases. The certified attorneys forming our team understand that personalized service is paramount, dispensing legal advice tailored to each client’s individual needs. Priding ourselves on excellent communication skills and extensive knowledge of Personal Injury Law makes us an irreplaceable ally during complex litigation processes which allows us to ensure maximum compensation deserved by victims due to others’ negligence.

Operating with utmost efficacy across various facets within the realm of personal injury—be it work accidents, car crashes or medical malpractice—we have secured favorable outcomes time after time again. Wielding this level of experience uniquely enables us at Carlson Bier to handle your case proficiently even amidst potential hurdles.

When you’ve been wronged owing to another’s imprudence anywhere including Geneva — Choose Carlson Bier; competent champions relentless in pursuit towards justice.

Meet Our Attorneys
About Carlson Bier

Personal Injury Lawyers in Geneva Illinois

At Carlson Bier, we take pride in our reputation as a preeminent personal injury law firm based in Illinois. Over the years, our seasoned attorneys have meritoriously shielded and advocated for countless clients who have suffered the unfortunate fate of sustaining injuries due to someone else’s negligence or willful discretion. We firmly believe that representing injured individuals involves more than just perfunctory legal counsel; it’s about providing robust support, sound advice, and fostering an environment where our client can regain their life back with dignity.

Personal Injury is not abbreviatedly confined to accidents alone; indeed it encompasses a wide array of situations ranging from dog bites to workplace mishaps, defective products mishandling, and even emotional distress resulting from traumatizing events like defamation. Our expert team at Carlson Bier provides comprehensive aid across these facets turning toward uncompromising justice for those unjustly hurt.

To elucidate further:

• Automobile Accidents: If you are a victim or collateral damage in an automobile accident because of some else’s reckless driving , our attorneys offer diligent representation targeting fair redress.

• Dangerous Drugs: When pharmaceutical companies allow dangerous medications to make their way into the consumer market breaching safety regulations, we ensure they are held accountable.

• Medical Malpractice: Doctors taking Hippocratic Oath rarely constitute error but when they do by way of negligent pharmacological administration or botched surgical procedures their accountability must never be shrugged off. At Carlson Bier., we safeguard the interests of such patients judiciously.

• Slips and Falls: Often misjudged trivialities; slip & fall injuries may sometimes result in grave repercussions hampering mobility permanence. Our practiced lawyers possess expert proficiency handling these complexities securing deserved compensations for afflicted individuals.

We understand that navigating through personal injury laws can be daunting to say the least – traumatic at worst – especially when oneself or a loved one is grappling with physical ailments concomitant with severance emotional distress. That’s where our seasoned, empathetic attorneys step in; offering patient guidance based on years of legal training, citing available options precisely and strategically working to win your case.

At Carlson Bier, we take a personalized approach towards every client with precision and utmost discretion. Each case is unique and treated so – assessed individually adhering closely to its unique circumstances recognizing that no two personal injury cases are identical.

While representation in court forms the crux of our services, we believe our role transcends beyond the courtroom walls. Our attorneys provide extensive advice about dealing with medical treatments expenses management assisting with insurance claims processes, all while ensuring you retain peace of mind focusing solely one thing – recovery.

We genuinely believe that being forearmed is forewarned but that can only come about from absolute understanding of your rights as injured individuals . Our solicitors arm you aptly clarifying intricate details underpinning Personal Injury law empowering not just informed decisions but more importantly your rightful place within Illinois’ justice system predominantly recognized making sure you aren’t left lacking amidst your predicament.

Equipped with an impressive track record proving consistent triumphs against top-level defense firms and insurance companies alike, Carlson Bier sets a beacon moment upholding victim’s rights above all else thereby forging ahead ensuring deserving claimants secure the compensation they deserve without undue delay or unnecessary hassle bear.

If you’ve been injured due to someone else’s disregard for safety it’s important not to face this ordeal alone. Let us stand by your side during these trying times guiding throughout steering clear from pitfalls typically awaiting uninformed clients. Find out how much your case could be worth by clicking on the button below. Trust in experience trust in integrity-trust in Carlson Bier!

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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 Geneva

Bicycle Incidents

Proficient in legal representation for persons injured in bicycle accidents due to other parties' lack of care or risky conditions.

Burn Burns

Offering adept legal help for individuals of major burn injuries caused by mishaps or recklessness.

Medical Carelessness

Delivering specialist legal services for clients affected by medical malpractice, including negligent care.

Products Accountability

Taking on cases involving unsafe products, extending professional legal assistance to consumers affected by faulty goods.

Senior Mistreatment

Representing the rights of the elderly who have been subjected to misconduct in nursing homes environments, ensuring fairness.

Fall & Tumble Injuries

Skilled in handling fall and trip accident cases, providing legal services to sufferers seeking redress for their harm.

Birth Harms

Delivering legal support for kin affected by medical incompetence resulting in birth injuries.

Vehicle Mishaps

Collisions: Committed to aiding victims of car accidents obtain reasonable payout for hurts and harm.

Two-Wheeler Incidents

Dedicated to providing representation for individuals involved in bike accidents, ensuring justice for traumas.

Truck Mishap

Ensuring adept legal advice for persons involved in semi accidents, focusing on securing adequate claims for injuries.

Building Incidents

Committed to representing employees or bystanders injured in construction site accidents due to oversights or recklessness.

Cerebral Traumas

Specializing in providing specialized legal advice for individuals suffering from cognitive injuries due to incidents.

Dog Attack Harms

Adept at managing cases for victims who have suffered traumas from canine attacks or beast attacks.

Pedestrian Crashes

Dedicated to legal assistance for foot-travelers involved in accidents, providing comprehensive support for recovering compensation.

Unfair Demise

Striving for loved ones affected by a wrongful death, delivering understanding and expert legal guidance to ensure restitution.

Spinal Cord Damage

Focused on assisting individuals with paralysis, offering professional legal guidance to secure justice.

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