City of Park Ridge v. Clarendon American Insurance Co.

2017 IL App (1st) 170453 (Ill. App., 2017)

Words & Phrases

Limits Of Liability

Trial Judge

Sophia H. Hall

Appellate Judge

Lavin

Holding

Medical Incident Malpractice "per occurrence" limit applied to paramedics’ failure to provide treatment to teenager suffering drug overdose, and not the “completed operations” aggregate limit.

Fact Summary

This appeal arises from the trial court’s order, granting summary judgment to defendant
Clarendon American Insurance Company (Clarendon). On appeal, plaintiffs City of Park Ridge
(Park Ridge) and its excess carrier, High-Level Excess Liability Pool (HELP), contend that the
trial court erroneously granted defendant’s motion for summary judgment because the court
erred in determining that emergency medical services fell within the scope of the “Products-
Completed Operations Hazard” provision under the insurance policy, which affected how much
Clarendon would have to pay in two separate claims. We reverse the trial court’s order of
summary judgment in Clarendon’s favor and remand the case for the trial court to enter summary
judgment for plaintiffs Park Ridge and HELP.

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