Applying Illinois law, the 7th U.S. Circuit Court of Appeals recently held that an umbrella insurer had no cause of action against an insured for failure to settle within the insured’s retained limit. North American Elite Insurance Co. v. Menard, Inc., No. 21-1813, 2022 U.S. App. Lexis 21592 (7th Cir. Aug. 4).The insurer North American, was represented by Walker Wilcox Matousek LLP of Chicago. Menard was represented by Reed Smith LLP of Chicago.A customer of Menard, owner of a chain of home improvement stores …