Pekin Insurance Company (pekin Insurance Company, Appellant) v. Jack O. Wilson (jack O. Wilson, Appellee)

Summary

The court held that an insurer determining its duty to defend may consider pleadings beyond the underlying complaint when the policy contains a self-defense exception to an intentional-act exclusion and the additional pleadings raise a genuine issue concerning that exception. Because the insured’s counterclaim alleged that he acted in self-defense, the pleadings potentially brought the claims within coverage and triggered the duty to defend. The court affirmed the appellate court’s reversal of judgment on the pleadings and reinstatement of the insured’s counterclaim against the insurer.