Case Explained: WESLEY J. GIBSON v. CHUBB NATIONAL INSURANCE COMPANY

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-07-13

The Seventh Circuit affirmed the district court’s entry of partial summary judgment in favor of Chubb National Insurance Company, holding that the insurer properly limited its liability for the loss of contents to a $25,000 sublimit under the plaintiff’s homeowner’s policy. The court applied Illinois law, which requires interpreting insurance policies according to their plain, ordinary, and popular meaning to give effect to the parties’ intent. Under the specific “Deluxe Contents” coverage at issue, the policy defined “business property” as furniture, supplies, equipment, inventory, books, records, or electronic data processing property “used to conduct your business,” with “business” broadly defined to include any activity intended to realize financial gain on a full-time, part-time, or occasional basis. The court rejected the plaintiff’s argument that the term “business property” was limited to traditional office assets or required exclusive business use. Applying the rule of *noscitur a sociis*, the court determined that the modifier “used to conduct your business” applied to all items in the list, not just the final item, and that the broad definition of “business” encompassed Gibson’s operation of Pine Manor as a luxury lodging and events venue. Because the mansion’s furnishings, artwork, and decor were overwhelmingly used to attract guests and facilitate the commercial rental business, they qualified as business property subject to the $25,000 cap. The court noted that only items stored in locked areas inaccessible to guests (such as a wine cellar and gun safe) remained excluded from this classification. Consequently, the insurer’s denial of the remaining contents claim was not “vexatious and unreasonable” under § 155 of the Illinois Insurance Code, nor did it constitute a deceptive practice under the Illinois Consumer Fraud Act, rendering Gibson’s statutory claims meritless. The judgment for the insurer stands, leaving Gibson with only the $25,000 payment already made for business property losses.

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