The Illinois Appellate Court ruled on September 30, 2026, that Mt. Hawley Insurance Company is not required to indemnify Stone Development Group (SDG) for a wrongful death case involving the death of Ramiro Godinez. The court found that Godinez was considered an employee of SDG at the time of his fatal accident, which triggered an employee exclusion in the insurance policy. This decision affects the estate of Godinez, which sought damages from SDG, and clarifies the application of insurance policy exclusions in similar cases.
The case, Mt. Hawley Insurance Co v. Stone Development Group, Inc., docket number 1-25-0465, arose from a tragic incident on a construction site in Waukegan, Illinois. Godinez was injured while performing carpentry work when he fell from a raised forklift and later died from his injuries. His estate filed a wrongful death suit against SDG, claiming negligence. However, Mt. Hawley, which provided insurance coverage to SDG, contended that it had no duty to defend or indemnify SDG due to the employee exclusion in its policy.
The dispute began when the estate of Godinez claimed that SDG was responsible for his death due to negligence in managing the construction site. In response, Mt. Hawley filed a declaratory judgment action, seeking a ruling that it had no obligation to cover SDG in the wrongful death case. The insurance company argued that Godinez was an employee of SDG at the time of the accident, which meant the policy's employee exclusion applied.
During the trial, the court examined various pieces of evidence, including testimony from SDG's vice president, John Stone, and the OSHA report detailing the accident. The court ultimately ruled in favor of Mt. Hawley, stating that the employee exclusion was applicable. The court found that Godinez was indeed an employee of SDG, which exempted the insurance company from liability under its policy.
The court's opinion, delivered by Presiding Justice Quish, stated, "The term 'employee' must be given its plain and ordinary meaning... Godinez was an employee of SDG for purposes of the employee exclusion in Mt. Hawley’s policies." Justices Lyle and Ocasio concurred with this ruling. The court's decision emphasized the importance of clearly defined roles and responsibilities in workplace safety and insurance coverage.
This ruling has significant implications for future cases involving insurance coverage and workplace injuries. It reinforces the notion that insurance companies can rely on employee exclusions to deny coverage when an individual is classified as an employee at the time of injury. This decision may influence how employers and insurance companies approach liability in similar circumstances, potentially leading to more stringent hiring practices and clearer definitions of employment relationships.
Moving forward, the estate of Godinez may have limited options for appealing this ruling. The court's decision is final unless further legal action is taken. There are no related cases pending that could impact this ruling directly, but it may set a precedent for how insurance policies are interpreted in cases involving employee injuries.