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7 Illinois opinions name it 1 courts 1991–2026 1 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 |
|---|---|---|
Simmons v. Homatasgreen2 sentences2015Melbourn asserts that the other allegations are either surplusage or conclusions, which cannot be considered, and that plaintiffs thus failed to allege any specific facts that trigger liability under section 876 of the Restatement (Second) of Torts. ¶ 29 Both parties discuss a number of cases dealing with in-concert liability under section 876 of the Restatement (Second) of Torts, but two are particularly instructive: one from our supreme court, Simmons v. Homatas, 236 Ill. 2d 459 (2010), and one from our appellate district, Sanke v. Bechina, 216 Ill. 2015Melbourn asserts that the other allegations are either surplusage or conclusions, which cannot be considered, and that plaintiffs thus failed to allege any specific facts that trigger liability under section 876 of the Restatement (Second) of Torts. ¶ 29 Both parties discuss a number of cases dealing with in-concert liability under section 876 of the Restatement (Second) of Torts, but two are particularly instructive: one from our supreme court, Simmons v. Homatas, 236 Ill. 2d 459 (2010), and one from our appellate district, Sanke v. Bechina, 216 Ill. | 3 | 3 |
Umble v. Sandy McKie and Sons, Inc.green2 sentences2026But as Umble stated: “We do not equate failing to prevent certain conduct with actively encouraging that conduct.” Id. at 451-52 . ¶ 91 In short, we do not find any evidence supporting a finding of “substantial assistance” within the meaning of section 876 and our precedent. ¶ 92 Plaintiff Otherwise Cannot Establish Liability Under Section 876(c) Because Menards’ Conduct, “Separately Considered,” Was Not A Breach of Duty ¶ 93 Our finding that there is no “substantial assistance” is dispositive in precluding plaintiff from establishing liability under section 876(c) of the Restatement. 2008See Umble, 294 Ill. | 2 | 3 |
Wolf v. Liberisgreen2 sentences2008Continuing with this temporal/physical proximity idea, On Stage next points to Wolf v. Liberis, 153 Ill. 2008Continuing with this temporal/physical proximity idea, On Stage next points to Wolf v. Liberis, 153 Ill. | 2 | 3 |
Iseberg v. Grossgreen2 sentences2008On Stage also points to Iseberg v. Gross, 366 Ill. 2008On Stage also points to Iseberg v. Gross, 366 Ill. | 2 | 2 |
Young v. Bryco Armsgreen2 sentences2008On Stage also points to Young v. Bryco Arms, 213 Ill. 2d 433, 448 (2004), for the proposition that comment d to section 876 of the Restatement does not provide an answer to the question of whether a defendant’s alleged conduct constitutes a legal cause of a claimed injury. 2008On Stage also points to Young v. Bryco Arms, 213 Ill. 2d 433, 448 (2004), for the proposition that comment d to section 876 of the Restatement does not provide an answer to the question of whether a defendant's alleged conduct constitutes a legal cause of a claimed injury. | 2 | 2 |
Sanke v. Bechinagreen2 sentences2015Melbourn asserts that the other allegations are either surplusage or conclusions, which cannot be considered, and that plaintiffs thus failed to allege any specific facts that trigger liability under section 876 of the Restatement (Second) of Torts. ¶ 29 Both parties discuss a number of cases dealing with in-concert liability under section 876 of the Restatement (Second) of Torts, but two are particularly instructive: one from our supreme court, Simmons v. Homatas, 236 Ill. 2d 459 (2010), and one from our appellate district, Sanke v. Bechina, 216 Ill. 2015Melbourn asserts that the other allegations are either surplusage or conclusions, which cannot be considered, and that plaintiffs thus failed to allege any specific facts that trigger liability under section 876 of the Restatement (Second) of Torts. ¶ 29 Both parties discuss a number of cases dealing with in-concert liability under section 876 of the Restatement (Second) of Torts, but two are particularly instructive: one from our supreme court, Simmons v. Homatas, 236 Ill. 2d 459 (2010), and one from our appellate district, Sanke v. Bechina, 216 Ill. | 1 | 3 |
Simmons v. Homatasgreen1 sentence2026Moreover (in contrast to the two drivers in Fortae), it is undisputed that Menards’ agent Holan was not even present when Brannan attempted to secure the pipe himself. -23- 1-25-0882 ¶ 89 We reiterate that, for liability under section 876, the “defendant must actively do something to facilitate another’s tortious conduct.” Simmons v. Homatas, 386 Ill. App. 3d 998, 1006 (2008). | 1 | 1 |
Fortae v. Hollandgreen2 sentences2026Id. at 708 . 2026Plaintiff largely relies on Fortae v. Holland, 334 Ill. App. 3d 705, 717 (2002), which found “substantial assistance” to support imposition of in concert liability under section 876(b). ¶ 81 Forte concerned a crash involving two vehicles that were working together to transport a manufactured home. | 1 | 1 |
Rogers v. Reagangreen1 sentence2020Rogers v. Reagan, 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 |
|---|---|---|
Sheffler v. Commonwealth Edison Co.
green
2 sentences2015In the present case, therefore, we consider whether, taken as true, plaintiffs’ allegations, as well as any reasonable inferences that arise from them (Doe, 213 Ill. 2d at 28 ), construed in the light most favorable to plaintiffs (Sheffler, 2011 IL 110166, ¶ 61 ), are sufficient to establish a cause of action for in-concert liability under section 876 of the Restatement (Second) of Torts. ¶ 34 We conclude that plaintiffs have sufficiently pleaded a cause of action for in-concert liability under section 876 of the Restatement (Second) of Torts. 2015In the present case, therefore, we consider whether, taken as true, plaintiffs’ allegations, as well as any reasonable inferences that arise from them (Doe, 213 Ill. 2d at 28 ), construed in the light most favorable to plaintiffs (Sheffler, 2011 IL 110166, ¶ 61 ), are sufficient to establish a cause of action for in-concert liability under section 876 of the Restatement (Second) of Torts. ¶ 34 We conclude that plaintiffs have sufficiently pleaded a cause of action for in-concert liability under section 876 of the Restatement (Second) of Torts. | 2 | 2015–2015 |
DOE EX REL. v. Chicago Bd. of Educ.
green
2 sentences2015In the present case, therefore, we consider whether, taken as true, plaintiffs’ allegations, as well as any reasonable inferences that arise from them (Doe, 213 Ill. 2d at 28 ), construed in the light most favorable to plaintiffs (Sheffler, 2011 IL 110166, ¶ 61 ), are sufficient to establish a cause of action for in-concert liability under section 876 of the Restatement (Second) of Torts. ¶ 34 We conclude that plaintiffs have sufficiently pleaded a cause of action for in-concert liability under section 876 of the Restatement (Second) of Torts. 2015In the present case, therefore, we consider whether, taken as true, plaintiffs’ allegations, as well as any reasonable inferences that arise from them (Doe, 213 Ill. 2d at 28 ), construed in the light most favorable to plaintiffs (Sheffler, 2011 IL 110166, ¶ 61 ), are sufficient to establish a cause of action for in-concert liability under section 876 of the Restatement (Second) of Torts. ¶ 34 We conclude that plaintiffs have sufficiently pleaded a cause of action for in-concert liability under section 876 of the Restatement (Second) of Torts. | 2 | 2015–2015 |
Greenfield v. Brannan
neutral
1 sentence2026For this additional reason, we also determine that plaintiff cannot establish Menards’ liability pursuant to section 876(c). ¶ 95 CONCLUSION ¶ 96 For the foregoing reasons, we affirm the circuit court’s entry of summary judgment in favor of Menards. ¶ 97 Affirmed. -25- 1-25-0882 Greenfield v. Brannan, 2026 IL App (1st) 250882 Decision Under Review: Appeal from the Circuit Court of Cook County, No. 23-L-4536; the Hon. | 1 | 2026–2026 |
Borcia v. Hatyina
neutral
2 sentences2015If the encouragement or assistance is a substantial factor in causing the resulting tort, the one giving it is himself a tortfeasor and is responsible for the consequences of the other’s act. *** [The rule] likewise applies to a person who knowingly gives substantial aid to another who, as he knows, intends to do a tortious act.” -8- 2015 IL App (2d) 140559 ¶ 27 In the present case, plaintiffs contend that the trial court erred when it dismissed count VI after finding that they had not alleged sufficient facts to trigger liability under section 876 of the Restatement (Second) of Torts. 2015As to count VI, the court found that plaintiffs had “alleged insufficient facts to establish ‘substantial assistance or encouragement’ for establishing a duty by Melbourn to attach under -5- 2015 IL App (2d) 140559 section 876 of the Restatement (Second) of Torts.” The trial court further found that the only facts plaintiffs alleged were that “defendant Melbourn provided and consumed alcohol and drugs with defendant Hatyina.” The trial court determined that there was no section 876 liability on the facts alleged. ¶ 17 The trial court also dismissed count VII on the basis that, “[i]f there is n | 1 | 2015–2015 |
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.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.