Hankins, 305 Ill.App.3d at 1093, 239 Ill.Dec. 394, 713 N.E.2d 1244. ¶ 12 This court disagreed with Hankins in Michael Nicholas, Inc. v. Royal Insurance Co. of America, 321 Ill.App.3d 909, 255 Ill.Dec. 82, 748 N.E.2d 786 (2001). In Michael Nicholas, which involved a construction subcontract agreement between the plaintiff and a developer, the plaintiff agreed to indemnify and hold harmless the developer from all claims attributable in whole or part to the plaintiff's negligence.

Hankins, 305 Ill. App. 3d at 1093. ¶ 13 This court disagreed with Hankins in Michael Nicholas, Inc. v. Royal Insurance Co., 321 Ill. App. 3d 909 (2001). In Michael Nicholas, which involved a construction subcontract agreement between the plaintiff and a developer, the plaintiff agreed to indemnify and hold harmless the developer from all claims attributable in whole or part to the plaintiff's negligence.

Konami, 326 Ill. App.3d at 879. Plaintiff acknowledges that this court's decision in Michael Nicholas, Inc. v. Royal Insurance Co. of America, 321 Ill. App.3d 909 (2001), controls here. Plaintiff asks us to reject it, however.

309 Ill. App. 3d at 692-93. Next, the Second District in Michael Nicholas, Inc. v. Royal Insurance Co. of America, 321 Ill. App. 3d 909 (2001), also rejected the Hankins decision. The Second District found the policy provided coverage. It stated,

Several of the cases cited by Premiere are factually inapposite to the instant case. See Gibson Assocs., Inc. v. Home Ins. Co., 966 F. Supp. 468 (N.D. Tex. 1997); Michael Nicholas, Inc. v. Royal Ins. Co. of Am., 748 N.E.2d 786 (Ill.App.Ct. 2001). These cases each involved a factual scenario similar to if Sumrall had sued Santa Fe directly, instead of Ensco.

In that case—and in every case discussed by the Illinois Supreme Court in coming to its conclusion—the definition of "insured contract" did not require, as it does here, that the "bodily injury" or "property damage" be caused, in whole or in part, by the insured. See id; Hankins v. Pekin Ins. Co., 713 N.E.2d 1244, 1248 (Ill. App. Ct. 1999); Christy-Foltz, Inc. v. Safety Mutual Casualty Corp., 722 N.E.2d 1206 (2000); Michael Nicholas, Inc. v. Royal Insurance Co. of America, 748 N.E.2d 786 (2001); West Bend Mutual Insurance Co. v. Mulligan Masonry Co., 786 N.E.2d 1078 (2003). When considering the history of the "insured contract" definition, that makes sense.

Ambiguous provisions in which an insurer seeks to limit its liability are read in the familiar contra proferentem mode: They are "construed most strongly against the insurer and in favor of the insured" (State Farm, 103 Ill.App.3d at 255, 430 N.E.2d at 646, citing Squire v. Economy Fire Cas. Co., 69 Ill.2d 167, 179, 370 N.E.2d 1044, 1049 (1977) to the identical effect).Michael Nicholas, Inc. v. Royal Ins. Co., 321 Ill. App.3d 909, 914, 748 N.E.2d 786, 791 (2d Dist. 2001) identifies the two important considerations that support such a rule: (1) the intent of an insured in purchasing an insurance policy is to obtain coverage, and therefore any ambiguity jeopardizing coverage should be construed consistent with the insured's intent; and (2) the insurer is the drafter of the policy and could have drafted the ambiguous provision clearly and specifically.

In attempting to resolve a dispute between parties regarding the proper interpretation of the language of an insurance policy, a court should first seek to determine the parties' intent from the language of the insurance contract itself. E.I. DuPont, 686 A.2d at 156; Michael Nicholas, Inc. v. Royal Ins. Co., 748 N.E.2d 786, 790 (Ill.App., 2d Dist. 2001); Conagra v. Arkwright Mut. Ins. Co., 64 F. Supp.2d 754, 759 (N.D.Ill. 1999). In so doing, the court must construe the policy "as a whole."

Another element of contract construction is the doctrine that generally insurance policies are construed in favor of the insured, in this case, AMN, because "(1) the intent of an insured in purchasing an insurance policy is to obtain coverage, and therefore any ambiguity jeopardizing such coverage should be construed consistent with the insured's intent; and (2) the insurer is the drafter of the policy and could have drafted the ambiguous provision clearly and specifically." Michael Nicholas, Inc. v. Royal Ins. Co. of America, 748 N.E.2d 786, 791 (Ill.App.Ct. 2001). See also Winter v. Minnesota Mut. Life Ins. Co., 199 F.3d 399, 409 (7th Cir. 1999) ("If the term is ambiguous, the court must construe the term against the insurer and in favor of the insured."

Moreover, a court will not interpret a contract in a manner that would render any provision meaningless. See Michael Nicholas, Inc. v. Royal Insurance Co. of America, 321 Ill. App. 3d 909, 915-16, 748 N.E.2d 784 (2001). Construing all of the terms of the uninsured motorist limits-of-liability provisions, we determine that only one reasonable interpretation of the limits-of-liability provisions exists and reject the Roth court's finding of an ambiguity.