Pekin Ins. Co. v. TOVAR SNOW PROFESSIONALS, 361 Ill. Dec. 168

Pekin Insurance issued a CGL policy to Dunleavy Concrete; Tovar Snow Professionals sought coverage as an additional insured under that policy.
Holland sued Tovar and Dunleavy for personal injuries from Holland's slip-and-fall during snow removal; Tovar tendered defense to Pekin.
The endorsement at issue provides 'Additional Insured' status for written construction contracts, with the insured added for ongoing operations and/or completed operations.
Pekin argued the endorsement limits coverage to construction contracts, because 'construction' appears in the heading, not the body text.
The circuit court granted summary judgment for Tovar; Pekin appealed, arguing the heading limited coverage.
The appellate court affirmed, holding that heading language cannot modify the plain text of the policy and that the policy text covered a written contract during the policy period.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the heading 'Written Construction Contract' limit coverage to construction contracts?	Pekin: heading restricts to construction contracts, excluding snow removal.	Tovar: text unambiguously covers any written contract during the policy period.	Heading cannot limit coverage; policy text governs.

Barth v. State Farm Fire & Casualty Co., 228 Ill.2d 163 (2008) (heading cannot modify the plain meaning of policy text)
Nudi Auto RV & Boat Sales, Inc. v. John Deere Insurance Co., 328 Ill.App.3d 523 (2002) (title/heading text not controlling when not reflected in substantive language)
Daniels v. Corrigan, 382 Ill.App.3d 66 (2008) (statutory headings not controlling over specific provisions)
Illinois Bell Telephone Co. v. Illinois Commerce Comm'n, 362 Ill.App.3d 652 (2005) (headings cannot override plain text; avoid undue reliance on organizational devices)
Guillen v. Potomac Insurance Co. of Illinois, 203 Ill.2d 141 (2003) (insurer's duty to defend construed liberally in favor of insured)