In a dispute between two insurers regarding which had a duty to defend in the underlying lawsuit, the federal district court denied one insurer's motion to join the underlying plaintiff as a necessary party. Amerisure Ins. Co. v. Burlington Ins. Group, Inc., 2025 U.S. Distl LEXIS 144927 (N.D. Ill. July 29, 2025).

Amerisure sued Burlington Insurance Group, Inc. (TBIC) for a declaratory judgment that TBIC owed coverge to Sollitt Construction Company and Chicago Park District in the underlying action. The Park District hired Sollitt for a renovation project. Sollitt procured a CGL policy from Amerisure covering Sollitt and the Park District as an additional insured. Sollitt then subcontracted with International Equipment, Inc. (IEI) to perform scaffolding work. Under the subcontract, IEI had to obtain primary additional insured coverage for Sollitt and Park District related to IEI's work. IEI obtained a cGL policy from TBIC.