State and federal cases applying Illinois law conflict on whether proximate cause can be considered in deciding what caused a loss for purposes of all risk property insurance policies. As recently noted in 4220 Kildare, LLC v. Regent Ins. Co., 2020 IL App (1st) 181840, Para. 28, 31-33, such policies cover policyholders for “all fortuitous losses not resulting from misconduct or fraud, unless the policy contains a specific provision expressly excluding the loss from coverage.” Although that decision did not concern the …