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Skaperdas v. Country Cas. Ins. Co.

2013 IL App (4th) 120986 (Ill. App., 2013)

Words & Phrases

Agent/Broker: Duty To Procure

Trial Judge

Hon. Jeffrey B. Ford

Appellate Judge

Presiding Justice Steigmann


Insurance agent owed a duty of care to insured to procure automobile insurance even though agent was not an insurance broker.

Fact Summary

In an action arising from defendant insurance agent’s failure to obtain the automobile insurance coverage plaintiff requested, the trial court’s decision that defendant did not owe a duty of care to plaintiff in procuring the coverage because he was an “agent” rather than a “broker” was reversed, since section 2-2201 of the Illinois Insurance Placement Liability Act eliminated the common-law distinction between insurance agents and brokers for purposes of the duty of care.