resolution claim (Illinois) · Go Syfert
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resolution claim in Illinois

34 Illinois opinions name it 2 courts 1985–2025 6 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.

Followed or applied (14)

CaseFollowedCited
DeSMET EX REL. v. County of Rock Islandgreen
ill · 2006 · cited in 5 Illinois opinions naming this issue, 2011–2016
2 sentences

2016See DeSmet, 219 Ill. 2d at 509 (“[W]e assume a defendant owes a duty, for the sake of analysis, in order to expedite the resolution of an immunity issue.”).

2016See DeSmet, 219 Ill. 2d at 509 (“[W]e assume a defendant owes a duty, for the sake of analysis, in order to expedite the resolution of an immunity issue.”).

45
Cunha v. Shapirogreen
nyappdiv · 2007 · cited in 2 Illinois opinions naming this issue, 2025–2025
2 sentences

2025Rather, it is “ ‘a conditional settlement.’ ” Pinske, 2015 IL App (1st) 150537 , ¶ 23 (quoting Cunha v. Shapiro, 837 N.Y.S.2d 160, 163 (App. Div. 2007)). “ ‘The condition of the agreement is that the jury render a verdict that falls outside the range of the high-low agreement.

2025Rather, - 31 - No. 1-23-0087 it is “ ‘a conditional settlement.’ ” Pinske, 2015 IL App (1st) 150537 , ¶ 23 (quoting Cunha v. Shapiro, 837 N.Y.S.2d 160, 163 (App. Div. 2007)). “ ‘The condition of the agreement is that the jury render a verdict that falls outside the range of the high-low agreement.

22
Murray v. Chicago Youth Centergreen
ill · 2007 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011See DeSmet v. County of Rock Island, 219 Ill. 2d 497, 509 (2006) (assuming defendant owed a duty, “for the sake of analysis, in order to expedite the resolution of an immunity issue”), superseded on other grounds by statute as stated in Murray v. Chicago Youth Center, 224 Ill. 2d 213 (2007).

2011See DeSmet v. County of Rock Island, 219 Ill. 2d 497, 509 (2006) (assuming defendant owed a duty, “for the sake of analysis, in order to expedite the resolution of an immunity issue”), superseded on other grounds by statute as stated in Murray v. Chicago Youth Center, 224 Ill. 2d 213 (2007).

22
People v. K.S.green
illappct · 2008 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011See K.S., 387 Ill.

2011See K.S., 387 Ill.

22
Marsh v. Evangelical Covenant Churchgreen
ill · 1990 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006A "claim" for purposes of Rule 304(a) "is any right, liability or matter raised in an action." Marsh v. Evangelical Covenant Church of Hinsdale, 138 Ill. 2d 458, 465 (1990).

2006A “claim” for purposes of Rule 304(a) “is any right, liability or matter raised in an action.” Marsh v. Evangelical Covenant Church of Hinsdale, 138 Ill. 2d 458, 465 (1990).

22
People v. Cejagreen
ill · 2003 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006As we may reject an ineffective assistance of counsel claim in a criminal case on the basis of lack of prejudice, assuming counsel’s deficient performance, arguendo, for purposes of analytical expedience (see People v. Ceja, 204 Ill. 2d 332, 358 (2003)), so may we assume a defendant owes a duty, for the sake of analysis, in order to expedite the resolution of an immunity issue.

2006As we may reject an ineffective assistance of counsel claim in a criminal case on the basis of lack of prejudice, assuming *1039 counsel's deficient performance, arguendo, for purposes of analytical expedience (see People v. Ceja, 204 Ill.2d 332, 358 , 273 Ill.Dec. 796 , 789 N.E.2d 1228 (2003)), so may we assume a defendant owes a duty, for the sake of analysis, in order to expedite the resolution of an immunity issue.

22
Grauer v. Clare Oaksgreen
illappct · 2019 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025Grauer, 2019 IL App (1st) 180835, ¶¶ 126, 152 .

11
Eddy v. Kerrgreen
illappct · 1981 · cited in 1 Illinois opinions naming this issue, 2022–2022
1 sentence

2022Eddy v. Kerr, 96 Ill.

11
Fort v. Smithgreen
illappct · 1980 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021(Fort v. Smith, 85 Ill.

11
Kim v. Alvey, Inc.green
illappct · 2001 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020See Kim v. Alvey, Inc., 322 Ill.

11
Van Meter v. Darien Park Dist.green
ill · 2003 · cited in 1 Illinois opinions naming this issue, 2013–2013
1 sentence

2013“The purpose of a section 2-619 motion to dismiss is to dispose of issues of law and easily proved issues of fact at the outset of litigation.” Van Meter v. Darien Park District, 207 Ill. 2d 359, 367 (2003).

11
Jessee v. Amoco Oil Co.green
illappct · 1992 · cited in 1 Illinois opinions naming this issue, 2013–2013
1 sentence

2013“Where there is a resolution of a claim by virtue of a settlement, and the terms of the settlement are made known to the court, there has been a preliminary showing of good faith which creates a presumption of validity.” Jessee v. Amoco Oil Co., 230 Ill.

11
Marconi v. Chicago Heights Police Pension Boardgreen
ill · 2007 · cited in 1 Illinois opinions naming this issue, 2011–2011
1 sentence

2011See, e.g., id. at 531-43 .

11
Ratkovich v. Hamiltongreen
illappct · 1994 · cited in 1 Illinois opinions naming this issue, 1998–1998
1 sentence

1998See Ratkovich v. Hamilton, 267 Ill.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (15)

CaseCitedYears
Allis-Chalmers Corp. v. Lueck green
scotus · 1985
2 sentences

1987(Lueck v. Aetna Life Insurance Co. (1984), 116 Wis. 2d 559 , 342 N.W.2d 699 .) The United States Supreme Court disagreed, holding that where, as there, the resolution of the State claim “is substantially dependent upon analysis of the terms of an agreement made between the parties in a labor contract” the claim is either a section 301 claim or one “preempted by Federal labor contract law.” ( 471 U.S. 202, 220 , 85 L.

1987(Lueck v. Aetna Life Insurance Co. (1984), 116 Wis. 2d 559 , 342 N.W.2d 699 .) The United States Supreme Court disagreed, holding that where, as there, the resolution of the State claim “is substantially dependent upon analysis of the terms of an agreement made between the parties in a labor contract” the claim is either a section 301 claim or one “preempted by Federal labor contract law.” ( 471 U.S. 202, 220 , 85 L.

31986–1987
Pinske v. Allstate Property and Casualty Insurance Company green
illappct · 2015
2 sentences

2025Rather, it is “ ‘a conditional settlement.’ ” Pinske, 2015 IL App (1st) 150537 , ¶ 23 (quoting Cunha v. Shapiro, 837 N.Y.S.2d 160, 163 (App. Div. 2007)). “ ‘The condition of the agreement is that the jury render a verdict that falls outside the range of the high-low agreement.

2025Rather, - 31 - No. 1-23-0087 it is “ ‘a conditional settlement.’ ” Pinske, 2015 IL App (1st) 150537 , ¶ 23 (quoting Cunha v. Shapiro, 837 N.Y.S.2d 160, 163 (App. Div. 2007)). “ ‘The condition of the agreement is that the jury render a verdict that falls outside the range of the high-low agreement.

22025–2025
McComb v. Seestadt green
illappct · 1981
2 sentences

1992(McComb v. Seestadt (1981), 93 Ill.

1985(McComb v. Seestadt (1981), 93 Ill.

21985–1992
Bituminous Ins. Cos. v. Ruppenstein neutral
illappct · 1986
2 sentences

1992(Bituminous Insurance Cos. v. Ruppenstein (1986), 150 Ill.

1989App. 3d 402 , 501 N.E.2d 907 , this court noted that the presumption of validity is created whenever there is a resolution of a claim by virtue of a release or covenant.

21989–1992
Snoddy v. Teepak, Inc. green
illappct · 1990
2 sentences

1992Where there is a resolution of a claim by virtue of a settlement, and the terms of the settlement are made known to the court, there has been a preliminary showing of good faith which creates a presumption of validity. ( Snoddy v. Teepak, Inc. (1990), 198 Ill.App.3d 966, 969 , 145 Ill.Dec. 64 , 556 N.E.2d 682 .) Because public policy favors the peaceful and voluntary resolution of disputes through settlement, any assertion of bad faith must be proved by clear and convincing evidence by the party claiming absence of good faith.

1992Where there is a resolution of a claim by virtue of a settlement, and the terms of the settlement are made known to the court, there has been a preliminary showing of good faith which creates a presumption of validity. ( Snoddy v. Teepak, Inc. (1990), 198 Ill.App.3d 966, 969 , 145 Ill.Dec. 64 , 556 N.E.2d 682 .) Because public policy favors the peaceful and voluntary resolution of disputes through settlement, any assertion of bad faith must be proved by clear and convincing evidence by the party claiming absence of good faith.

21992–1992
Meyer v. Murray green
illappct · 1979
2 sentences

1992App. 3d 106 , 387 N.E.2d 878 .) Where there is a resolution of a claim by virtue of a release or covenant, a presumption of validity is created.

1985App. 3d 106 , 387 N.E.2d 878 .) Where there is a resolution of a claim by virtue of a release or covenant, a presumption of validity is created.

21985–1992
Wasmund v. Metropolitan Sanitary District green
illappct · 1985
2 sentences

1992App. 3d 926 , 482 N.E.2d 351 .) Further, the settling defendants state that a presumption of validity is created whenever there is a resolution of a claim by virtue of a release or covenant.

1986“Where there is a resolution of a claim by virtue of a release or covenant, a presumption of validity is created. [Citation.] Thereafter, the party challenging the release carries the burden of proving any assertion of invalidity.” (Wasmund v. Metropolitan Sanitary District (1985), 135 Ill.

21986–1992
Bartley v. University Asphalt Co. green
ill · 1986
2 sentences

1986Since a resolution of the claim against the union was "`substantially dependent upon analysis of the terms of [the collective-bargaining] agreement'" ( Bartley v. University Asphalt Co. (1986), 111 Ill.2d 318, 332 , quoting Allis-Chalmers Corp. v. Lueck (1985), 471 U.S. 202, 220 , 85 L.Ed.2d 206, 221 , 105 S.Ct. 1904, 1916 ), the claim was preempted by Federal labor-contract law.

1986Since a resolution of the claim against the union was “ ‘substantially dependent upon analysis of the terms of [the collective-bargaining] agreement’ ” (Bartley v. University Asphalt Co. (1986), 111 Ill. 2d 318, 332 , quoting Allis-Chalmers Corp. v. Lueck (1985), 471 U.S. 202, 220 , 85 L.

21986–1987
Continental Illinois National Bank & Trust Co. v. Protos Shipping Inc. green
ilnd · 1979
1 sentence

2024Likewise, subsection (a)(1) allows a trial court to dismiss if it does not have jurisdiction of the subject matter of a cause, “provided the defect cannot be removed by a transfer of the case to a court having jurisdiction.” Id. § 2- 619(a)(1).

12024–2024
Calanca v. D & S MANUFACTURING CO. green
illappct · 1987
1 sentence

1995Calanca involved an employment contract between an Illinois resident and a Wisconsin corporation, wherein the parties agreed that "in the event of any litigation ***, [the] proper forum for the resolution of such claim shall be the Circuit Court for Jackson County, Wisconsin.” (Calanca, 157 Ill.

11995–1995
People v. Geneva green
illappct · 1990
1 sentence

1993App. 3d at 1026 , 554 N.E.2d at 562 .) The jury here resolved the matter against defendant; we cannot say such a resolution was in error.

11993–1993
Argueta v. Baltimore & Ohio Chicago Terminal Railroad green
illappct · 1991
2 sentences

1992Argueta v. Baltimore & Ohio Chicago Terminal R.R. (1991), 224 Ill.App.3d 11, 22 , 166 Ill.Dec. 428 , 586 N.E.2d 386 ; Banks v. R.D.

1992Argueta v. Baltimore & Ohio Chicago Terminal R.R. (1991), 224 Ill.App.3d 11, 22 , 166 Ill.Dec. 428 , 586 N.E.2d 386 ; Banks v. R.D.

11992–1992
Lingle v. Norge Division of Magic Chef, Inc. green
scotus · 1988
2 sentences

1989(Lingle, 486 U.S. 399 , 100 L.

1989(Lingle, 486 U.S. 399 , 100 L.

11989–1989
Gonzalez v. Prestress Engineering Corp. green
ill · 1986
2 sentences

1987Bartley v. University Asphalt Co. (1986), 111 Ill. 2d 318, 332 , 489 N.E.2d 1367 ; Gonzalez v. Prestress Engineering Corp. (1986), 115 Ill. 2d 1, 9 , 503 N.E.2d 308, 312 , quoting Allis-Chalmers Corp. v. Lueck (1985), 471 U.S. 202, 220 , 85 L.

1987Bartley v. University Asphalt Co. (1986), 111 Ill. 2d 318, 332 , 489 N.E.2d 1367 ; Gonzalez v. Prestress Engineering Corp. (1986), 115 Ill. 2d 1, 9 , 503 N.E.2d 308, 312 , quoting Allis-Chalmers Corp. v. Lueck (1985), 471 U.S. 202, 220 , 85 L.

11987–1987
Lueck v. Aetna Life Insurance green
wis · 1984
2 sentences

1987(Lueck v. Aetna Life Insurance Co. (1984), 116 Wis. 2d 559 , 342 N.W.2d 699 .) The United States Supreme Court disagreed, holding that where, as there, the resolution of the State claim “is substantially dependent upon analysis of the terms of an agreement made between the parties in a labor contract” the claim is either a section 301 claim or one “preempted by Federal labor contract law.” ( 471 U.S. 202, 220 , 85 L.

1987(Lueck v. Aetna Life Insurance Co. (1984), 116 Wis. 2d 559 , 342 N.W.2d 699 .) The United States Supreme Court disagreed, holding that where, as there, the resolution of the State claim “is substantially dependent upon analysis of the terms of an agreement made between the parties in a labor contract” the claim is either a section 301 claim or one “preempted by Federal labor contract law.” ( 471 U.S. 202, 220 , 85 L.

11987–1987

Statutes the citing opinions construe

IL § 210 ILCS 50/3.150 (4) IL § 735 ILCS 5/2-619 (4) IL § 745 ILCS 10/1-101 (4) IL § 745 ILCS 10/1-101.1 (4) USC § 29u.s.c.185 (4) IL § 745 ILCS 10/4-102 (3) IL § 755 ILCS 5/27-6 (3)

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.

Where else courts name it

TX 62 (1966–2026) CT 51 (1989–2025) CA 44 (1929–2026) IL 34 (1985–2025) PA 33 (1902–2026) NC 25 (1989–2026) FL 21 (1974–2022) OH 18 (1986–2022) MA 12 (1993–2025) MD 12 (1976–2017) MS 11 (1928–2022) WA 11 (2003–2014) MO 11 (1959–2024) OK 11 (1982–2017) NY 11 (1964–2026) NJ 9 (1945–2026) GA 8 (1994–2023) OR 7 (1987–2017) WI 7 (1998–2024) KY 6 (2010–2025) DE 6 (1976–2026) WV 6 (1982–2009) IN 6 (2006–2026) WY 6 (2004–2011) TN 5 (2001–2007) AL 5 (1992–2026) CO 5 (1985–2011) MI 5 (1983–2025) KS 5 (1995–2024) VT 4 (2007–2015) AZ 4 (1975–2024) VA 4 (1982–1999) LA 4 (1989–2021) HI 3 (1994–2016) DC 3 (1978–2013) AK 3 (2008–2024) IA 3 (1986–2016) MT 3 (1998–2017) NE 2 (2001–2006) NV 2 (1995–2000) MN 2 (1990–2016) ID 2 (1987–2014)

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.

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