Robert R. McCormick Foundation v. Arthur J. Gallagher Risk Management Services, Inc.

Summary

The Illinois Supreme Court held that the common‑interest exception to the attorney‑client privilege does not apply where the parties lack an insured‑insurer relationship, so the Foundations’ communications with counsel remain privileged. Accordingly, the Court reversed the lower court’s order compelling discovery of those communications, affirmed the denial of a stay, vacated the contempt order, and remanded for further proceedings.