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“Marisa Saber” “implied coinsured doctrine” “Illinois” “Auto Owners Ins. Co. v. Callaghan” “Dix Mutual Ins. Co. v. LaFramboise” “landlord tenant”
An Illinois Appellate Court recently issued an opinion which may make subrogating against a negligent tenant more challenging. Auto Owners Ins. Company a/s/o John Ellis v. Thomas Callaghan, 952 N.E.2d 119 (Ill.App.3d 2011) involved a landlord’s carrier that sued a tenant who was leasing a house. The plaintiff insurer alleged that the tenant was negligent in starting...