The Illinois Supreme Court has once again corrected an error of insurance policy interpretation by the Illinois Appellate Court, Fifth District and held that the mechanical device exclusion in the policy in question was not ambiguous. The case is State Farm Mut. Auto. Ins. Co. v. Elmore, 2020 IL 125441.

At issue in this case was the enforceability of a "mechanical device" exclusion in an automobile policy that was issued by State Farm Mutual Automobile Insurance Company (State Farm). Keith Elmore was injured while unloading grain from a truck owned by his father, Ardith Sheldon Elmore (Sheldon). Kent helped Sheldon with his grain farm operation in 2013, and was filling an empty grain truck with grain when an accident occurred caused by an auger with no protective shield. In the accident Kent lost his right leg below the knee, and surgery was later required to remove the leg just above the knee.

Kent filed a negligence suit against Sheldon which eventually settled. In exchange for releasing all claims against Sheldon, Kent received $1.9 million from State Farm Fire and Casualty and two other insurers. Kent reserved his right to pursue additional coverage under the auto policy that covered the grain truck, a 2002 Ford International 4900. Sheldon was the named insured under that policy. State Farm filed a complaint for declaratory judgment asking the court to determine and adjudicate the parties' rights and liabilities under the policy.