No Duty to Defend Alleged Negligent Training Claim Under Simulator Training School's Premises Liability Coverage

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In Pekin Insurance Company v. Recurrent Training Center, Inc., -- N.E.2d --, 2011 WL 1515516 (Ill. App. Ct. April 20, 2011), the Appellate Court of Illinois affirmed a trial court's decision on summary judgment that no duty to defend was owed to a simulator training school under a policy providing premises liability coverage for claims alleging negligent training of a pilot.

The insured, Recurrent Training Center, provided flight simulator and classroom instruction on the operation of Cessna 421B aircraft to a pilot, who at some point thereafter crashed while piloting a Cessna for business purposes on behalf of his employer. The crash, which occurred 170 miles from the insured's facility, resulted in the death of the pilot and three others.

Pekin Insurance Company insured the school under a commercial general liability policy including products/completed operations, but a "Limitation of Coverage to Designated Premises or Project" endorsement limited coverage to bodily injury "arising out of the ownership, maintenance or use of the premises shown in the Schedule and operations necessary or incidental to those premises."

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