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69 Illinois opinions name it 2 courts 2004–2026 32 in the last five years
The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Dopkeen v. Whitakergreen2 sentences2017In reviewing a dismissal pursuant to both sections 2-615 and 2-619, -5 No. 1-16-2068 "we accept all well-pleaded facts in the complaint as true and draw all reasonable inferences from those facts in favor of the nonmoving party." Dopkeen v. Whitaker, 399 Ill. 2017In reviewing a dismissal pursuant to both sections 2-615 and 2-619 of the Code (735 ILCS 5/2-615, 2-619 (West 2014)), “we accept all well-pleaded facts in the complaint as true and draw all reasonable inferences from those facts in favor of the nonmoving party.” Dopkeen v. Whitaker, 399 Ill. | 3 | 3 |
Rodriguez v. Sheriff's Merit Commissiongreen2 sentences2026See Rodriguez v. Sheriff’s Merit Comm’n of Kane County, 218 Ill. 2d 342, 357 (2006) (reviewing the circuit court’s dismissal of the plaintiff’s complaint for administrative review). ¶ 29 A motion to dismiss pursuant to section 2-619.1 of the Code allows a party to combine a section 2-615 motion to dismiss with a section 2-619 motion to dismiss. 735 ILCS 5/2-615, 2-6- 19, 2-619.1 (West 2022); Grassroots Collaborative v. City of Chicago, 2020 IL App (1st) 192099, ¶ 21 . 2026See Rodriguez v. Sheriff’s Merit Commission of Kane County, 218 Ill. 2d 342, 357 (2006) (reviewing the circuit court’s dismissal of the plaintiff’s complaint for administrative review). ¶ 30 A motion to dismiss pursuant to section 2-619.1 of the Code allows a party to combine a section 2-615 motion to dismiss with a section 2-619 motion to dismiss. 735 ILCS 5/2-619.1 (West 2022); Grassroots Collaborative v. City of Chicago, 2020 IL App (1st) 192099 , ¶ 21. | 2 | 2 |
Becker v. Zellnergreen2 sentences2026ANALYSIS ¶ 19 A motion to dismiss pursuant to section 2-619.1 of the Code (id. § 2-619.1) allows parties to combine motions brought pursuant to sections 2-615 (id. § 2-615) and 2-619 (id. § 2-619) into one pleading but requires the combined motion to be divided into parts, with each part limited to the points or grounds of either section 2-615 or section 2-619. 6 ¶ 20 “[A] motion to dismiss under section 2-615 differs significantly from a motion for involuntary dismissal under section 2-619.” Becker v. Zellner, 292 Ill. 2025ANALYSIS ¶ 13 A motion to dismiss pursuant to section 2-619.1 (735 ILCS 5/2-619.1 (West 2020)) of the Code of Civil Procedure allows parties to blend motions brought pursuant to section 2-615 (id. § 2-615) and 2-619 (id. § 2-619) into one pleading but requires the combined motion to be divided into parts, with each part limited to the points or grounds of either section 2-615 or section 2-619. 4 ¶ 14 “[A] motion to dismiss under section 2-615 differs significantly from a motion for involuntary dismissal under section 2-619.” Becker v. Zellner, 292 Ill. | 2 | 2 |
Cwikla v. Sheirgreen2 sentences2026App. 3d 116, 122 (1997). “[A] section 2-615 motion is based on the pleadings rather than on the underlying facts.” Cwikla v. Sheir, 345 Ill. 2025App. 3d 116, 122 (1997). “[A] section 2-615 motion is based on the pleadings rather than on the underlying facts.” Cwikla v. Sheir, 345 Ill. | 2 | 2 |
Downey v. Wood Dale Park Districtgreen2 sentences2022See, e.g., Downey v. Wood Dale Park District, 286 Ill. App. 3d 194, 199 (1997) (combined motion to dismiss pursuant to section 2-619.1 of the Code is proper if movant indicates under which section of the Code each part of the combined motion to dismiss is brought). 2005See Downey v. Wood Dale Park District, 286 Ill.App.3d 194, 199 , 221 Ill.Dec. 549 , 675 N.E.2d 973 (1997) (combined motion to dismiss pursuant to section 2-619.1 of the Code is proper if movant indicates under which section of the Code each part of the combined motion to dismiss is brought). | 2 | 2 |
Aurelius v. State Farm Fire and Cas. Co.green2 sentences2017Defendants filed a motion to dismiss under section 2-619.1 of the Code of Civil Procedure (Code) (735 ILCS 5/2-619.1 (West 2014)), combining arguments for dismissal under section 2-615 and section 2-619 of the Code (735 ILCS 5/2-615, 2-619 (West 2014)). ¶4 “A section 2-615 motion attacks the legal sufficiency of the plaintiff’s claims, while a section 2-619 motion admits the legal sufficiency of the claims but raises defects, defenses, or other affirmative matter, appearing on the face of the complaint or established by external submissions, that defeats the action.” Aurelius v. State Farm Fir 2017Defendants filed a motion to dismiss under section 2-619.1 of the Code of Civil Procedure (Code) (735 ILCS 5/2-619.1 (West 2014)), combining arguments for dismissal under section 2-615 and section 2-619 of the Code (735 ILCS 5/2-615, 2-619 (West 2014)). ¶4 “A section 2-615 motion attacks the legal sufficiency of the plaintiff’s claims, while a section 2-619 motion admits the legal sufficiency of the claims but raises defects, defenses, or other affirmative matter, appearing on the face of the complaint or established by external submissions, that defeats the action.” Aurelius v. State Farm Fir | 2 | 2 |
Morris v. Harvey Cycle and Camper, Inc.green2 sentences2014Morris v. Harvey Cycle & Camper, Inc., 392 Ill. 2014Morris v. Harvey Cycle & Camper, Inc., 392 Ill. | 2 | 2 |
Lawson v. City of Chicagogreen2 sentences2004Lawson v. City of Chicago , 278 Ill. 2004Lawson v. City of Chicago , 278 Ill. | 2 | 2 |
Reynolds v. Jimmy John's Enterprises, LLCgreen2 sentences2020Reynolds v. Jimmy John’s Enterprises, LLC, 2013 IL App (4th) 120139, ¶ 20 . 2017To avoid unnecessary complications and confusion ***, trial courts should sua sponte reject such motions and give the defendants who filed them the opportunity (if they wish) to file a section 2-619.1 motion that meets the statutory requirements.” Howle, 2012 IL App (4th) 120207, ¶ 73 , 978 N.E.2d 1132 ; see also Reynolds v. Jimmy John’s Enterprises, LLC, 2013 IL App (4th) 120139, ¶ 21 , 988 N.E.2d 984 (recommending trial courts take similar measures as those described in Howle); Lavite v. Dunstan, 2016 IL App (5th) 150401, ¶ 21 , 58 N.E.3d 1270 (recommending trial courts take similar measures | 1 | 4 |
Hampton v. The Chicago Transit Authoritygreen2 sentences2026Hampton v. Chicago Transit Authority, 2018 IL App (1st) 172074, ¶ 19. 2023As explained in Hampton v. Chicago Transit Authority, 2018 IL App (1st) 172074 , ¶ 19: “Section 2-619.1 is a combined motion that incorporates sections 2-615 and 2-619 of the Code. [(735 ILCS 5/2-615, 2-619 (West 2020))]. | 1 | 3 |
Moorman Manufacturing Co. v. National Tank Co.green2 sentences2016On September 30, 2014, and December 12, 2014, the trial court granted the defendants’ motions, dismissing with prejudice the plaintiffs’ negligence counts (counts I, III, V, VII, IX, XI, XIII, XV, XVII, XIX, XX, XIII) pursuant to the economic loss doctrine articulated in Moorman, 91 Ill. 2d 69 . 2016On September 30, 2014, and December 12, 2014, the trial court granted the defendants’ motions, dismissing with prejudice the plaintiffs’ negligence counts (counts I, III, V, VII, IX, XI, XIII, XV, XVII, XIX, XX, XXIII) pursuant to the economic loss doctrine articulated in Moorman, 91 Ill. 2d 69 . | 1 | 3 |
Simmons v. Homatasgreen2 sentences2012Simmons v. Homatas, 236 Ill.2d 459, 477 , 338 Ill.Dec. 883 , 925 N.E.2d 1089 (2010). *1291 ¶ 9 Home Depot filed its motion to dismiss under section 2-619.1 of the Code (735 ILCS 5/2-619.1 (West 2008)). 2012Simmons v. Homatas, 236 Ill.2d 459, 477 , 338 Ill.Dec. 883 , 925 N.E.2d 1089 (2010). *1291 ¶ 9 Home Depot filed its motion to dismiss under section 2-619.1 of the Code (735 ILCS 5/2-619.1 (West 2008)). | 1 | 2 |
Orlak v. Loyola University Health Systemgreen1 sentence2026Orlak v. Loyola University Health System, 228 Ill. 2d 1, 7 (2007). ¶ 14 JPTS argues that the Village’s motion should have been rejected for failing to separately label each subpart under sections 2-615 or 2-619. | 1 | 1 |
Barbara's Sales, Inc. v. Intel Corp.green1 sentence2026See Barbara’s Sales, Inc. v. Intel Corp., 227 Ill. 2d 45, 59 (2007) (plaintiff is the master of their complaint). ¶ 13 A motion to dismiss pursuant to section 2-619.1 (735 ILCS 5/2-619.1) of the Code allows parties to blend motions brought pursuant to section 2-615 (735 ILCS 5/2-615 (West 2024)) and 2-619 (735 ILCS 5/2-619 (West 2024)) into one pleading but requires the combined motion to be divided into parts, with each part limited to the points or grounds of either section 2-615 or section 2-619. | 1 | 1 |
Beacham v. Walkergreen1 sentence2026Beacham v. Walker, 231 Ill. 2d 51, 57 (2008). -8- ¶ 29 In considering a combined motion to dismiss pursuant to section 2-619.1, we accept all well-pleaded facts in the complaint as true, drawing all inferences from the facts in favor of the non-moving party. | 1 | 1 |
| Illinois Road and Transportation Builders Ass'n v. County of Cookgreen | 1 | 1 |
| People v. Castleberrygreen | 1 | 1 |
People v. Luis R.green1 sentence2025See Castleberry, 2015 IL 116916, ¶ 15 , and Luis R., 239 Ill. 2d at 301 (both recognizing the exception). ¶ 15 For the reasons that follow, we hold that Muhammad failed to state a claim for mandamus relief because he did not set out any basis on which one could conclude the administrative action rule for a trial court’s subject matter jurisdiction applied to the traffic case. ¶ 16 A. Section 2-619.1 Standards ¶ 17 The trial court granted Walker’s motion to dismiss under section 2-619.1 of the Code, which combines arguments under sections 2-615 and 2-619 of the Code. | 1 | 1 |
| Dillon v. Evanston Hospitalgreen | 1 | 1 |
| McGee v. Snydergreen | 1 | 1 |
| Green v. Trinity International Universitygreen | 1 | 1 |
| Kovilic v. City of Chicagogreen | 1 | 1 |
| Cohen v. McDonald's Corp.green | 1 | 1 |
| Bunting v. Progressive Corp.green | 1 | 1 |
| Morris Ex Rel. Morris v. Williamsgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Schloss v. Jumper
green
2 sentences2025Schloss v. Jumper, 2014 IL App (4th) 121086, ¶ 15 . 2024Schloss v. Jumper, 2014 IL App (4th) 121086, ¶ 15 . | 6 | 2020–2025 |
Grassroots Collaborative v. City of Chicago
green
2 sentences2026See Rodriguez v. Sheriff’s Merit Comm’n of Kane County, 218 Ill. 2d 342, 357 (2006) (reviewing the circuit court’s dismissal of the plaintiff’s complaint for administrative review). ¶ 29 A motion to dismiss pursuant to section 2-619.1 of the Code allows a party to combine a section 2-615 motion to dismiss with a section 2-619 motion to dismiss. 735 ILCS 5/2-615, 2-6- 19, 2-619.1 (West 2022); Grassroots Collaborative v. City of Chicago, 2020 IL App (1st) 192099, ¶ 21 . 2026See Rodriguez v. Sheriff’s Merit Commission of Kane County, 218 Ill. 2d 342, 357 (2006) (reviewing the circuit court’s dismissal of the plaintiff’s complaint for administrative review). ¶ 30 A motion to dismiss pursuant to section 2-619.1 of the Code allows a party to combine a section 2-615 motion to dismiss with a section 2-619 motion to dismiss. 735 ILCS 5/2-619.1 (West 2022); Grassroots Collaborative v. City of Chicago, 2020 IL App (1st) 192099 , ¶ 21. | 4 | 2024–2026 |
Financial Freedom Acquisition, LLC v. Standard Bank and Trust Co.
neutral
2 sentences2016The trial court's written order stated, "The Court has considered the parties' briefs and the relevant case law, particularly Financial Freedom Acquisition, LLC v. Standard Bank & Trust Co., 2014 IL App (1st) 120982 and Westbank v. Maurer, 276 Ill. 2016The trial court’s written order stated, “The Court has considered the parties’ briefs and the relevant case law, particularly Financial Freedom Acquisition, LLC v. Standard Bank & Trust Co., 2014 IL App (1st) 120982 and Westbank v. Maurer, 276 Ill. | 3 | 2015–2016 |
Westbank v. Maurer
green
2 sentences2016The trial court's written order stated, "The Court has considered the parties' briefs and the relevant case law, particularly Financial Freedom Acquisition, LLC v. Standard Bank & Trust Co., 2014 IL App (1st) 120982 and Westbank v. Maurer, 276 Ill. 2016The trial court’s written order stated, “The Court has considered the parties’ briefs and the relevant case law, particularly Financial Freedom Acquisition, LLC v. Standard Bank & Trust Co., 2014 IL App (1st) 120982 and Westbank v. Maurer, 276 Ill. | 3 | 2015–2016 |
Edelman, Combs & Latturner v. Hinshaw & Culbertson
green
2 sentences2014A motion under section 2-619.1 allows a party to "combine a section 2-615 motion to dismiss based upon a plaintiff's substantially insufficient pleadings with a section 2- 619 motion to dismiss based upon certain defects or defenses." Edelman, Combs & Latturner v. Hinshaw & Culbertson, 338 Ill. 2014A motion under section 2-619.1 allows a party to “combine a section 2-615 motion to dismiss based upon a plaintiff’s substantially insufficient pleadings with a section 2-619 motion to dismiss based upon certain defects or defenses.” Edelman, Combs & Latturner v. Hinshaw & Culbertson, 338 Ill. | 3 | 2009–2014 |
Kennedy v. City of Chicago
green
2 sentences2026Kennedy v. City of Chicago, 2022 IL App (1st) 210492, ¶ 16 . ¶ 11 A. The Combined Motion to Dismiss ¶ 12 Initially, JPTS argues that reversal is necessary because the Village’s motion to dismiss did not properly designate the components of its combined motion to dismiss. 2026Kennedy v. City of Chicago, 2022 IL App (1st) 210492, ¶ 16 . | 2 | 2026–2026 |
Zander v. Carlson
green
2 sentences2025Still, “[a] motion to dismiss does not admit conclusions of law or conclusory factual allegations unsupported by specific facts alleged in the complaint.” Zander v. Carlson, 2020 IL 125691, ¶ 25 . 2025Still, “[a] motion to dismiss does not admit conclusions -7- of law or conclusory factual allegations unsupported by specific facts alleged in the complaint.” Zander v. Carlson, 2020 IL 125691, ¶ 25 . | 2 | 2025–2025 |
Marshall v. Burger King Corp.
green
2 sentences2024Marshall, 222 Ill. 2d at 429 . 2022Marshall, 222 Ill. 2d at 429 ; Malinksi, 2014 IL App (2d) 130685, ¶ 6 . | 2 | 2022–2024 |
Atkinson v. Sinclair Refining Co.
red
2 sentences2020As grounds for their motion, they asserted that, under Atkinson, 370 U.S. 238 , and its progeny, union agents or employees like Carlson cannot be held personally liable for actions undertaken in the course of their employment in furtherance of collective bargaining rights, including grievance procedures such as the one involved in this case. 2020As grounds for their motion, they asserted that, under Atkinson, 370 U.S. 238 , and its progeny, union agents or employees like Carlson cannot be held personally liable for actions undertaken in the course of their employment in furtherance of collective bargaining rights, including grievance procedures such as the one involved in this case. | 2 | 2020–2020 |
Patrick Engineering, Inc. v. The City of Naperville
green
2 sentences2020Italia Foods, Inc. v. Sun Tours, Inc., 2011 IL 110350 , ¶ 9; Patrick Engineering, Inc. v. City of Naperville, 2012 IL 113148, ¶ 31 . 2020Italia Foods, Inc. v. Sun Tours, Inc., 2011 IL 110350 , ¶ 9; Patrick Engineering, Inc. v. City of Naperville, 2012 IL 113148, ¶ 31 . | 2 | 2020–2020 |
Howle v. Aqua Illinois, Inc.
green
2 sentences2013App. 3d 1079, 1086 , 801 N.E.2d 1208, 1214 (2003) (Second District) (section 2-619.1 does not permit a party to “submit evidentiary material going to the truth of the allegations contained in the complaint because a motion pursuant to either section 2-615 or 2-619 concedes the truth of all well-pleaded allegations”). ¶ 21 “[T]rial courts should not–and need not–accept for consideration combined motions under section 2-619.1 that do not meet these statutory requirements.” Howle, 2012 IL App (4th) 120207, ¶ 73 , 978 N.E.2d 1132 . 2013App. 3d 1079, 1086 , 801 N.E.2d 1208, 1214 (2003) (Second District) (section 2-619.1 does not permit a party to “submit evidentiary material going to the truth of the allegations contained in the complaint because a motion pursuant to either section 2-615 or 2-619 concedes the truth of all well-pleaded allegations”). ¶ 21 “[T]rial courts should not–and need not–accept for consideration combined motions under section 2-619.1 that do not meet these statutory requirements.” Howle, 2012 IL App (4th) 120207, ¶ 73 , 978 N.E.2d 1132 . | 2 | 2013–2017 |
People v. Thomas
green
2 sentences2015People v. Thomas, 2014 IL App (2d) 121001 , ¶ 94. 2015People v. Thomas, 2014 IL App (2d) 121001 , ¶ 94. | 2 | 2015–2015 |
Younge v. Berman
green
1 sentence2026Younge v. Berman, 2025 IL App (2d) 240354, ¶ 18 . | 1 | 2026–2026 |
Heck v. Humphrey
green
1 sentence2026Defendants argued that McCray failed to state a claim for ineffective assistance of counsel, that his claims are barred under the statute of limitations, and that his claims are barred by the holding of Heck v. Humphrey, 512 U.S. 477 (1994). | 1 | 2026–2026 |
| Northwestern Illinois Area Agency on Aging v. Basta green | 1 | 2025–2025 |
| EJ Construction 1 Corp. v. Pellegrino neutral | 1 | 2025–2025 |
| Thurman v. Champaign Park Dist. green | 1 | 2025–2025 |
| Cahokia Unit School District No. 187 v. Pritzker green | 1 | 2024–2024 |
| Solaia Technology, LLC v. Specialty Publishing Co. green | 1 | 2024–2024 |
| Glorioso v. Sun-Times Media Holdings, LLC green | 1 | 2023–2023 |
| Illinois Road & Transportation Builders Ass'n v. County of Cook green | 1 | 2022–2022 |
| The Matter of the Estate of Edmund Felix Hennel , , Also Known as Edmund Hennel green | 1 | 2021–2021 |
| Doe v. Coe green | 1 | 2021–2021 |
| Mareskas-Palcek v. Schwartz, Wolf & Bernstein, LLP green | 1 | 2020–2020 |
| Brockmeyer v. Duncan green | 1 | 2019–2019 |
| Stolfo v. Kindercare Learning Centers, Inc. green | 1 | 2019–2019 |
| McCarthy v. Taylor green | 1 | 2018–2018 |
| Lavite v. Dunstan green | 1 | 2017–2017 |
| Doe v. Catholic Diocese green | 1 | 2015–2015 |
| People v. Graves green | 1 | 2015–2015 |
| DeLuna v. Burciaga green | 1 | 2009–2009 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.