Once An Insurance Policy Is Issued the Insured Is No Longer An ''Applicant''

In Lee v. John Deere Insurance Co., 208 Ill. 2d 38, 43, 802 N.E.2d 774, 280 Ill. Dec. 523 (2003), the supreme court confirmed that, once a policy is issued, the insured is no longer an "applicant" with respect to that policy. Lee, 208 Ill. 2d at 50. However, it did not address whether a current policyholder may be an "applicant" with respect to some other policy in the future. Nor did its decision rest primarily on semantic distinctions. Rather, the court held that a rejection form received after the policy had been issued was not effective because, without already having a signed rejection form in hand, "under the plain language of the statute, the insurer could not have lawfully issued the policy without UM coverage equal to the bodily injury limits." Lee, 208 Ill. 2d at 51. As always, the language of the statute is the best determinant of the legislature's intent. Lee, 208 Ill. 2d at 43.