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Case Law Update: Uninsured Motorists in Illinois and Agency

The 1st District in Farmers Automobile Insurance Association v. Wroblewski, No. 1-06-3604 (May 2, 2008) 6th div. (O’MALLEY) reversed the trail court, holding that a release in favor of employer of driver of vehicle with which defendant’s insured vehicle collided, which specifically identifies the other driver and unambiguously provides that its execution releases all agents and employees of employer, serves to release employee driver. Therefore, trial court erred when allowed parol evidence to conclude that defendants could recover uninsured motorist benefits after employee’s insurer became insolvent.