Case Explained: ROBERT D. FERGUSON v. AON RISK SERVICES COMPANIES, INC., et al

Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-08-13 The Seventh Circuit affirmed the district court’s dismissal of Plaintiffs’ breach of contract and professional negligence claims against Aon Risk Services Companies, Inc. The court held that Clarendon America Insurance Company was not a third-party beneficiary of the 1996 and 1999 agreements between Aon and SCB because the contracts lacked explicit language or strong implications demonstrating an intent to confer a direct benefit on Clarendon rather than merely an incidental one. Regarding the professional negligence claim, the court ruled that under Illinois law, insurance brokers owe no duty to non-insured third parties to notify an insured’s carriers of claims made by those third parties against the insured. Additionally, the court determined that even if the claims were viable, they were time-barred under the two-year statute of limitations for actions against insurance producers in Illinois, as the alleged breaches occurred in 1999 and Plaintiffs had inquiry notice of the potential injury by 2012. Consequently, the judgment granting summary judgment to Aon and dismissing the negligence claim is affirmed. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.