IL · jury_instructions
Ill. Pattern Jury Instr. (Civil) 710.02
Insurance Bad Faith--Issues Made by the Pleadings
The plaintiff claims that as of [date on which the settlement demand within policy limits
was made or, if applicable, the date on which the plaintiff’s demand for settlement within policy
limits expired] [name of insurance company] had a reasonable opportunity to settle [name of
injured person]’s claim against [name of the insured party] within the limits of its policy.
The plaintiff further claims that as of [date on which the settlement demand within policy
limits was made or, if applicable, the date on which the plaintiff’s demand for settlement within
policy limits expired, there was both a reasonable probability of a finding of liability against [name
of the insured] and a reasonable probability of a recovery in favor of [name of injured person] and
against [name of the insured] in excess of the limits of its policy’s coverage.
[Set forth in simple form without undue emphasis or repetition those allegations of the
complaint as to the bad faith of the insurance company which have not been withdrawn or ruled
out by the court and are supported by the evidence.]
The plaintiff further claims that o ne or more of the foregoing proximately caused the
judgment in excess of the policy limits to be entered against [name of insured].
[Name of insurance company] [denies that it did any of the things claimed by the plaintiff,]
denies that it acted in bad faith in doing any of the things claimed by the plaintiff, and denies that
any claimed act or omission on the part of [name of insurance company] proximately caused the
judgment in excess of the policy limits to be entered against [name of insured].
[[Name of insurance company] also sets up the following affirmative defense(s):]
[Here set forth in simple form without undue emphasis or repetition those affirmative
defenses (except contributory negligence) in the answer which have not been withdrawn or ruled
out by the court and are supported by the evidence.]
[The plaintiff denies that (summarize affirmative defense(s)).]
Provenance
- Source
- illinoiscourts.gov
- Retrieved
- 2026-08-20
- Edition
- 2026-08-19
- Content hash
e4e09d4063d2f06c33c4c514eef515dbfcdb62a5fd0e237f902776a605ce793f
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