Applying Illinois law, a federal district court has held that an insurer did not have a duty to defend or indemnify for a lawsuit that was filed and dismissed prior to the policy period and later refiled during the policy period. Navigators Specialty Ins. Co. v. B.D. McClure & Assocs., Ltd., 2020 WL 5909067 (N.D. Ill. Oct. 6, 2020).
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