Unambiguous policy defeats last-antecedent grammar rule

Insurance Matters

By Don R. Sampen

Don R. Sampen is a member of the appellate practice group of Clausen, Miller P.C., where he focuses on appellate, commercial and insurance-related litigation. He also teaches insurance law at Loyola University Chicago School of Law. His column appears twice monthly.

Posted May 20, 2019 3:48 PM

The 2nd District Appellate Court recently rejected application of the last-antecedent rule of grammatical construction in finding an umbrella liability policy unambiguous.The insurer in State Farm Mutual Automobile Insurance Co. v. Murphy, 2019 IL App (2d) 180154 (March 29, 2019), was represented by SmithAmundsen LLC. Much Shelist P.C. represented the parties seeking coverage under the State Farm policy.James Hollander, deceased, was driving an automobile owned by Sandra Wendland in 2015 when a collision occurred in …

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