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Illinois’ Broad Duty to Defend Rule Is Put to the Test, and Prevails, for Now: Philadelphia Indemnity Insurance Co. v. Chicago Title Insurance Co.

By David Rosenfield, Attorney, Reed Smith LLP Illinois and numerous other jurisdictions adhere to the long-standing rule that if an insurer has a duty to defend a single count in a multi-count complaint, then it has a duty to defend the entire complaint. When an insurer recently tried to avoid...