Los Angeles, CA — Consumer Watchdog (CW) announced today that an Administrative Law Judge has denied the Illinois Department of Insurance’s (IDOI) attempt to make a “special appearance” to oppose motions to compel disclosure of communications between IDOI and the California Department of Insurance (CDI) in the hearing concerning a requested $1 billion rate increase for State Farm General Insurance Company. The Court held that IDOI may not use a non-party workaround to argue the merits in a Proposition 103 rate case and noted there was no showing why CDI could not adequately defend any confidentiality claims itself.
IDOI had sought leave to file its own opposition to the pending motions to compel—aimed at obtaining information exchanged between IDOI and CDI—thereby aligning with CDI’s effort to prevent disclosure and against consumers’ right to transparency under Prop 103. The motions to compel were filed by Consumer Watchdog and State Farm.
The information IDOI and CDI seek to keep from public view involves State Farm’s own financial condition—information at the very heart of the insurer’s request for a billion-dollar rate increase. Those financial details are directly relevant to the extraordinary variances State Farm seeks to justify a 30 percent premium hike. Proposition 103 guarantees the public a right to see and challenge the evidence insurers rely upon before California families face massive new costs. Without disclosure of this type of financial information, the record would lack the details needed to test State Farm’s justification for its proposed rate hike.
“This ruling preserves Prop. 103’s sunlight. IDOI tried to align with CDI to keep key inter-agency communications out of the record without accepting the obligations of party status. The Court said no. If an out-of-state regulator wants to argue against disclosure in a California rate case, it must follow California’s rules,” said William Pletcher, Litigation Director at Consumer Watchdog.
The Court has not yet ruled on Consumer Watchdog’s motion to compel CDI to produce these same IDOI–CDI communications. But today’s order ensures that IDOI will not be permitted to influence the disclosure ruling without complying with California law, including Proposition 103.
Consumer Watchdog led the charge opposing IDOI’s maneuver, filing an objection on September 3, 2025, explaining that California law controls in this California proceeding and that any comity concerns could be raised through CDI without inventing a novel non-party merits role for IDOI.
“Prop. 103 is about accountability and public access, not back-room secrecy. California law—not Illinois confidentiality provisions—governs here. This decision keeps the public’s seat at the table and keeps the record open,” said Ryan Mellino, staff attorney at Consumer Watchdog.
What the ruling means
• No non-party end-runs. The Court refused to authorize a “special appearance” for merits advocacy by IDOI; such advocacy is a general appearance that requires intervention under Prop 103.
• California law controls. Discovery and privileges are governed by California statutes and rules; Illinois confidentiality provisions cannot create new California privileges.
• CDI can speak for itself. The Court noted IDOI made no showing that CDI could not adequately defend against the motions to compel.
• Transparency preserved, motion pending. CW’s separate motion to compel CDI remains pending, and the Court will decide it on the merits—without IDOI attempting to influence the disclosure ruling unless it intervenes.
The Administrative Law Judge is scheduled to hear arguments on CW’s motion to compel at a public hearing at 1 PM on September 16 at CDI’s hearing room located at 300 South Spring Street, Los Angeles, 90013.
About Consumer Watchdog
Consumer Watchdog is a non-profit, non-partisan public-interest organization that advocates for taxpayers and consumers through litigation, advocacy, and education. Learn more at ConsumerWatchdog.org
