Relying On A Certificate Of Insurance? Better Read It First

Risk management law experts – notably those at International Risk Management Institute, Inc., whose outstanding website is a treasure trove of useful information — have warned for years that Certificates of Insurance are "one of the more dangerous documents that float between insureds, insurers, and a myriad of third parties. . . ." Proof can be found almost every week in the advance sheets; the latest is West Bend Mutual Ins. Co. v. Athens Construction Co. Inc., 2015 Ill. App. Unpub. LEXIS 255 (Ill. App. [1 Dist.] February 17, 2015).

Athens thought it was an Additional Insured. Athens had in its hands a Certificate of Insurance that said, expressly, that Athens was an Additional Insured: W. Bend Mut. Ins. Co., 2015 Ill. App. Unpub. LEXIS 255 at **4-5 ("'Athens Construction Co. Inc. is an Additional Insured. . . .'") (quoting the Certificate of Insurance). But Athens wasn't an Additional Insured, because the policy did not make Athens an Additional Insured. So held