Already have an account? Sign in instead.
You stay signed in for 30 days on this browser.
Continue with Google Continue with MicrosoftNo account yet? Create a free one.
We sent a six-digit code.
It expires in ten minutes, works once, and only in this browser. Five wrong tries void it. Send another code.
Your account is live and the Cloudflare checks are off for this browser.
10 Illinois opinions name it 1 courts 1997–2026 3 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 |
|---|---|---|
Ryan v. Fox Television Stations, Inc.green2 sentences2023Garrido, 2013 IL App (1st) 120466, ¶ 19 ; see also Ryan, 2012 IL App (1st) 120005, ¶ 26 (rejecting defendants’ argument that the claims were meritless because plaintiff failed to sufficiently plead a cause of action under the standard of section 2-615); Hammons, 2012 IL App (1st) 102644, ¶ 21 . 2013See Ryan, 2012 IL App (1st) 120005, ¶ 22 (noting that Sandholm made clear that immunity based on the Act is an affirmative matter that is properly brought under section 2-619 rather than section 2- 615); see also Hammons, 2012 IL App (1st) 102644, ¶ 21 . | 2 | 2 |
Misselhorn v. Doylegreen2 sentences2017After all, an unripe declaratory judgment action lacks an essential element of the cause of action, namely, an actual controversy (Underground Contractors Ass’n v. City of Chicago, 66 Ill. 2d 371, 375 (1977) (a controversy is “actual” only if “the underlying facts and issues of the case are not moot or premature” (emphasis added)), and a - 19 - complaint lacking even a single element is a legally insufficient complaint, subject to dismissal under section 2-615 (Misselhorn v. Doyle, 257 Ill. 2017After all, an unripe declaratory judgment action lacks an essential element of the cause of action, namely, an actual controversy (Underground Contractors Ass’n v. City of Chicago, 66 Ill. 2d 371, 375 (1977) (a controversy is “actual” only if “the underlying facts and issues of the case are not moot or premature” (emphasis added)), and a complaint lacking even a single element is a legally insufficient complaint, subject to dismissal under section 2-615 (Misselhorn v. Doyle, 257 Ill. | 2 | 2 |
Underground Contractors Ass'n v. City of Chicagogreen2 sentences2017After all, an unripe declaratory judgment action lacks an essential element of the cause of action, namely, an actual controversy (Underground Contractors Ass’n v. City of Chicago, 66 Ill. 2d 371, 375 (1977) (a controversy is “actual” only if “the underlying facts and issues of the case are not moot or premature” (emphasis added)), and a - 19 - complaint lacking even a single element is a legally insufficient complaint, subject to dismissal under section 2-615 (Misselhorn v. Doyle, 257 Ill. 2017After all, an unripe declaratory judgment action lacks an essential element of the cause of action, namely, an actual controversy (Underground Contractors Ass’n v. City of Chicago, 66 Ill. 2d 371, 375 (1977) (a controversy is “actual” only if “the underlying facts and issues of the case are not moot or premature” (emphasis added)), and a complaint lacking even a single element is a legally insufficient complaint, subject to dismissal under section 2-615 (Misselhorn v. Doyle, 257 Ill. | 2 | 2 |
Hammons v. Society of Permanent Cosmetic Professionalsgreen2 sentences2023Garrido, 2013 IL App (1st) 120466, ¶ 19 ; see also Ryan, 2012 IL App (1st) 120005, ¶ 26 (rejecting defendants’ argument that the claims were meritless because plaintiff failed to sufficiently plead a cause of action under the standard of section 2-615); Hammons, 2012 IL App (1st) 102644, ¶ 21 . 2013See Ryan, 2012 IL App (1st) 120005, ¶ 22 (noting that Sandholm made clear that immunity based on the Act is an affirmative matter that is properly brought under section 2-619 rather than section 2- 615); see also Hammons, 2012 IL App (1st) 102644, ¶ 21 . | 1 | 2 |
Seip v. Rogers Raw Materials Fund, L.P.green1 sentence2026The complaint also specifically alleged that “[Great American] breached the agreement with [Skyway]” and requested damages. ¶ 19 In counts 2 and 3 of its complaint, asserting claims of bad faith, Skyway reiterated its prior allegations and added that Great American “vexatiously and unreasonably delayed the settlement of [Skyway’s] claims” and that “Great American’s conduct-including its material misrepresentations, unreasonable denial of coverage, and shifting justifications-constitutes a 5 breach of its duty of good faith and fair dealing owed to [Skyway].” We note that, while “every contract | 1 | 1 |
Marshall v. Burger King Corp.green1 sentence2025We review de novo a trial court’s dismissal of a complaint under section 2-619.1, and we may affirm such dismissals on any basis supported by the record. -5- Madison County v. Illinois State Board of Elections, 2022 IL App (4th) 220169, ¶ 42 . ¶ 18 In determining whether a complaint was properly subject to dismissal under section 2-615, “ ‘we accept as true all well-pleaded facts and all reasonable inferences that may be drawn from those facts.’ ” Bueker v. Madison County, 2016 IL 120024 , ¶ 7 (quoting Marshall v. Burger King Corp., 222 Ill. 2d 422, 429 (2006)). | 1 | 1 |
Floyd Ex Rel. Floyd v. Rockford Park Dist.green1 sentence2012Floyd v. Rockford Park District, 355 Ill. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Hartz Const. v. Village of Western Springs
green
1 sentence2026The complaint also specifically alleged that “[Great American] breached the agreement with [Skyway]” and requested damages. ¶ 19 In counts 2 and 3 of its complaint, asserting claims of bad faith, Skyway reiterated its prior allegations and added that Great American “vexatiously and unreasonably delayed the settlement of [Skyway’s] claims” and that “Great American’s conduct-including its material misrepresentations, unreasonable denial of coverage, and shifting justifications-constitutes a 5 breach of its duty of good faith and fair dealing owed to [Skyway].” We note that, while “every contract | 1 | 2026–2026 |
Bueker v. Madison County Illinois
green
1 sentence2025We review de novo a trial court’s dismissal of a complaint under section 2-619.1, and we may affirm such dismissals on any basis supported by the record. -5- Madison County v. Illinois State Board of Elections, 2022 IL App (4th) 220169, ¶ 42 . ¶ 18 In determining whether a complaint was properly subject to dismissal under section 2-615, “ ‘we accept as true all well-pleaded facts and all reasonable inferences that may be drawn from those facts.’ ” Bueker v. Madison County, 2016 IL 120024 , ¶ 7 (quoting Marshall v. Burger King Corp., 222 Ill. 2d 422, 429 (2006)). | 1 | 2025–2025 |
Madison County, Illinois v. Illinois State Board of Elections
green
1 sentence2025We review de novo a trial court’s dismissal of a complaint under section 2-619.1, and we may affirm such dismissals on any basis supported by the record. -5- Madison County v. Illinois State Board of Elections, 2022 IL App (4th) 220169, ¶ 42 . ¶ 18 In determining whether a complaint was properly subject to dismissal under section 2-615, “ ‘we accept as true all well-pleaded facts and all reasonable inferences that may be drawn from those facts.’ ” Bueker v. Madison County, 2016 IL 120024 , ¶ 7 (quoting Marshall v. Burger King Corp., 222 Ill. 2d 422, 429 (2006)). | 1 | 2025–2025 |
Garrido v. Arena
green
1 sentence2023Garrido, 2013 IL App (1st) 120466, ¶ 19 ; see also Ryan, 2012 IL App (1st) 120005, ¶ 26 (rejecting defendants’ argument that the claims were meritless because plaintiff failed to sufficiently plead a cause of action under the standard of section 2-615); Hammons, 2012 IL App (1st) 102644, ¶ 21 . | 1 | 2023–2023 |
Sandholm v. Kuecker
green
1 sentence2012App. 3d 113 , 126 n.3 (2010). ¶ 21 At oral argument, defendants asserted that we should read the supreme court’s holding in Sandholm v. Kuecker, 2012 IL 111443 , that the Act applies only to meritless lawsuits should be read as applying to lawsuits that are subject to dismissal under section 2-615 for failure to state a claim or under section 2-619(a)(5) as being filed beyond the statute of limitations. 735 ILCS 5/2-615, 2-619(a)(5) (West 2008). | 1 | 2012–2012 |
Urbaitis v. Commonwealth Edison
green
2 sentences1997Urbaitis, 143 Ill. 2d at 475 , 575 N.E.2d at 555 . 1997Urbaitis, 143 Ill. 2d at 475 , 575 N.E.2d at 555 . | 1 | 1997–1997 |
Wieseman v. Kienstra, Inc.
green
1 sentence1997Wieseman v. Kienstra, Inc. , 237 Ill. App. 3d 721 (1992). | 1 | 1997–1997 |
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.