Chicago Hosp. Risk Pooling Program v. STATE MED. INTER-INS. EXCHANGE

The Chicago Hospital Risk Pooling Program (CHRPP) brought an action against defendant, the Illinois State Medical Inter-Insurance Exchange (ISMIE), under theories of equitable contribution, unjust enrichment, and quantum meruit to recover one-half of a settlement payment it made on behalf of a physician covered by both CHRPP and ISMIE. ISMIE filed an affirmative defense, alleging, inter alia, that CHRPP’s contribution claim was barred by the physician’s selective tender of his claim to CHRPP The trial court rejected ISMIE’s argument, holding that the selective tender rule applied only to…