Economy Fire & Casualty Co. v. State Farm Mutual Insurance Co

In Economy Fire & Casualty Co. v. State Farm Mutual Insurance Co., 153 Ill. App. 3d 378, 505 N.E.2d 1334, 106 Ill. Dec. 543 (1987), there were multiple grounds for excluding coverage, including the driver's transfer of title to his girlfriend to obtain valid plates following the suspension of his license, his intoxication on the night of the accident, and the forcible taking of the car keys from his girlfriend before driving away. Additionally, in affirming denial of coverage the Economy court focused on the "reasonable belief" of the driver, rather than the "entitled" aspect of the exclusion: "Economy has not raised the issue, and we need not decide, whether 'entitled' to use the car means the legal authority to drive a car so that Barton is thereby precluded from coverage on the sole fact that his driver's license was suspended." Economy, 153 Ill. App. 3d at 383, 505 N.E.2d at 1337.