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Economy Fire & Casualty Company v. Brumfield

384 Ill.App.3d 726, 894 N.E.2d 421, 323 Ill. Dec. 654 (4th dist. 2008)

Words & Phrases

Duty To Defend: Conflict Of Interest

Trial Judge


Appellate Judge



Insurer properly declined to defend insured’s son by filing a declaratory judgment action and Brumfield’s subsequent amended complaint did not create a conflict of interest because insurer’s duty to defend at the time was only reimbursement of defense costs, not involvement in the defense.