effect of the discovery rule (Illinois) · Go Syfert
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effect of the discovery rule in Illinois

27 Illinois opinions name it 2 courts 1982–2023 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.

Followed or applied (5)

CaseFollowedCited
Knox College v. Celotex Corp.green
ill · 1981 · cited in 12 Illinois opinions naming this issue, 1982–2023
2 sentences

2023App. 3d 690, 705 , 867 N.E.2d 1085, 1099-1100 (2007). ¶ 31 “The effect of the discovery rule is to postpone the starting of the period of limitations until the injured party knows or should have known of his injury.” Knox College v. Celotex Corp., 88 Ill. 2d 407, 414 , 430 N.E.2d 976, 979 (1981). “[T]he statute starts to run when a person knows or reasonably should know of his injury and also knows or reasonably should know that it was wrongfully caused.” Id. at 415 . ¶ 32 “Knowledge that an injury has been ‘wrongfully caused’ does not mean knowledge of a specific defendant’s negligent conduct

2023App. 3d 690, 705 , 867 N.E.2d 1085, 1099-1100 (2007). ¶ 31 “The effect of the discovery rule is to postpone the starting of the period of limitations until the injured party knows or should have known of his injury.” Knox College v. Celotex Corp., 88 Ill. 2d 407, 414 , 430 N.E.2d 976, 979 (1981). “[T]he statute starts to run when a person knows or reasonably should know of his injury and also knows or reasonably should know that it was wrongfully caused.” Id. at 415 . ¶ 32 “Knowledge that an injury has been ‘wrongfully caused’ does not mean knowledge of a specific defendant’s negligent conduct

312
Golla v. General Motors Corp.green
ill · 1995 · cited in 4 Illinois opinions naming this issue, 2004–2006
2 sentences

2004As our supreme court has explained: “To alleviate the harsh consequences that would flow from literal application of the limitations period, the judiciary created the ‘discovery rule.’ The effect of the discovery rule, which this court first adopted in Rozny v. Marnul (1969), 43 Ill. 2d 54, 72-73 , is to postpone the commencement of the relevant statute of limitations until the injured plaintiff knows or reasonably should know that he has been injured and that his injury was wrongfully caused. [Citation.] Since Rozny, the discovery rule has been applied to a wide variety of actions. [Citations

2004As our supreme court has explained: "To alleviate the harsh consequences that would flow from literal application of the limitations period, the judiciary created the 'discovery rule.' The effect of the discovery rule, which this court first adopted in Rozny v. Marnul (1969), 43 Ill. 2d 54, 72-73 , is to postpone the commencement of the relevant statute of limitations until the injured plaintiff knows or reasonably should know that he has been injured and that his injury was wrongfully caused. [Citation.] Since Rozny , the discovery rule has been applied to a wide variety of actions. [Citation

24
Nolan v. Johns-Manville Asbestosgreen
ill · 1981 · cited in 3 Illinois opinions naming this issue, 1990–2000
2 sentences

2000See Nolan v. Johns-Manville Asbestos, 85 Ill. 2d 161, 169 , 421 N.E.2d 864, 868 (1981).

1990The effect of the discovery rule is to postpone the starting of the period of limitations until the injured party knows or should have known of his injury. [Citations.] The difficulty in applying the discovery rule has been in giving meaning to the term commonly used stating the rule, ‘knows or should have known of his injury.’ ” ( 88 Ill. 2d at 414 .) The supreme court considered this difficulty and relied upon two earlier holdings in which it had explicated the rule and adopted a construction of it which was neither “narrow nor expansive.” ( 88 Ill. 2d at 414-15 .) Citing Witherell v. Weimer

23
Brdar v. Cottrell, Inc.green
illappct · 2007 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023App. 3d 690, 705 , 867 N.E.2d 1085, 1099-1100 (2007). ¶ 31 “The effect of the discovery rule is to postpone the starting of the period of limitations until the injured party knows or should have known of his injury.” Knox College v. Celotex Corp., 88 Ill. 2d 407, 414 , 430 N.E.2d 976, 979 (1981). “[T]he statute starts to run when a person knows or reasonably should know of his injury and also knows or reasonably should know that it was wrongfully caused.” Id. at 415 . ¶ 32 “Knowledge that an injury has been ‘wrongfully caused’ does not mean knowledge of a specific defendant’s negligent conduct

11
Wells v. Travisgreen
illappct · 1996 · cited in 1 Illinois opinions naming this issue, 2023–2023
2 sentences

2023App. 3d 690, 705 , 867 N.E.2d 1085, 1099-1100 (2007). ¶ 31 “The effect of the discovery rule is to postpone the starting of the period of limitations until the injured party knows or should have known of his injury.” Knox College v. Celotex Corp., 88 Ill. 2d 407, 414 , 430 N.E.2d 976, 979 (1981). “[T]he statute starts to run when a person knows or reasonably should know of his injury and also knows or reasonably should know that it was wrongfully caused.” Id. at 415 . ¶ 32 “Knowledge that an injury has been ‘wrongfully caused’ does not mean knowledge of a specific defendant’s negligent conduct

2023App. 3d 282, 287 , 672 N.E.2d 789, 793 (1996).

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 (10)

CaseCitedYears
Dancor International, Ltd. v. Friedman, Goldberg & Mintz green
illappct · 1997
2 sentences

2010The effect of the discovery rule is to “delay[ ] commencement of the statute of limitations until the plaintiff knows or reasonably should have known of the injury and that it may have been wrongfully caused.” Dancor, 288 Ill.

2010The effect of the discovery rule is to "dela[y] commencement of the statute of limitations until the plaintiff knows or reasonably should have known of the injury and that it may have been wrongfully caused." Dancor, 288 Ill.

52006–2010
Rozny v. Marnul green
ill · 1969
2 sentences

2004As our supreme court has explained: “To alleviate the harsh consequences that would flow from literal application of the limitations period, the judiciary created the ‘discovery rule.’ The effect of the discovery rule, which this court first adopted in Rozny v. Marnul (1969), 43 Ill. 2d 54, 72-73 , is to postpone the commencement of the relevant statute of limitations until the injured plaintiff knows or reasonably should know that he has been injured and that his injury was wrongfully caused. [Citation.] Since Rozny, the discovery rule has been applied to a wide variety of actions. [Citations

2004As our supreme court has explained: "To alleviate the harsh consequences that would flow from literal application of the limitations period, the judiciary created the 'discovery rule.' The effect of the discovery rule, which this court first adopted in Rozny v. Marnul (1969), 43 Ill. 2d 54, 72-73 , is to postpone the commencement of the relevant statute of limitations until the injured plaintiff knows or reasonably should know that he has been injured and that his injury was wrongfully caused. [Citation.] Since Rozny , the discovery rule has been applied to a wide variety of actions. [Citation

41982–2004
Hermitage Corp. v. Contractors Adjustment Co. green
ill · 1995
2 sentences

2019Hermitage, 166 Ill. 2d at 81 .

2018Hermitage , 166 Ill. 2d at 81 , 209 Ill.Dec. 684 , 651 N.E.2d 1132 .

32018–2019
Clark v. Western Union Telegraph Co. green
illappct · 1986
1 sentence

2002Pace relies on Clark v. Western Union Telegraph Co., 141 Ill.

12002–2002
Jackson Jordan, Inc. v. Leydig, Voit & Mayer green
ill · 1994
1 sentence

1995Jackson Jordan, Inc. v. Leydig, Voit & Mayer (1994), 158 Ill. 2d 240, 249 .

11995–1995
Pratt v. Sears Roebuck & Co. green
illappct · 1979
1 sentence

1994(Knox College v. Celotex Corp. (1981), 88 Ill. 2d 407, 414 , 430 N.E.2d 976, 979 .) "A plaintiff requesting application of the discovery rule must plead facts necessary to explain why the cause of action was not discovered sooner.” (Pratt v. Sears Roebuck & Co. (1979), 71 Ill.

11994–1994
Santa Claus Industries, Inc. v. First National Bank green
illappct · 1991
2 sentences

1994Santa Claus Industries, Inc. v. First National Bank (1991), 216 Ill.App.3d 231 , 159 Ill.

1994Santa Claus Industries, Inc. v. First National Bank (1991), 216 Ill.

11994–1994
Witherell v. Weimer green
ill · 1981
1 sentence

1990The effect of the discovery rule is to postpone the starting of the period of limitations until the injured party knows or should have known of his injury. [Citations.] The difficulty in applying the discovery rule has been in giving meaning to the term commonly used stating the rule, ‘knows or should have known of his injury.’ ” ( 88 Ill. 2d at 414 .) The supreme court considered this difficulty and relied upon two earlier holdings in which it had explicated the rule and adopted a construction of it which was neither “narrow nor expansive.” ( 88 Ill. 2d at 414-15 .) Citing Witherell v. Weimer

11990–1990
McDaniel v. La Salle Ambulance Service, Inc. green
illappct · 1982
1 sentence

1984(Knox College v. Celotex Corp. (1981), 88 Ill. 2d 407, 414-15 ; McDaniel v. LaSalle Ambulance Service, Inc. (1982), 108 Ill.

11984–1984
Mosby v. Michael Reese Hospital green
illappct · 1964
1 sentence

1982App. 2d 336 , 199 N.E.2d 633 .) The discovery rule represents the judiciary’s attempt to remedy this problem and “to alleviate what has been viewed as harsh results resulting from the literal application of the statute [of limitations].” (Knox College v. Celotex Corp. (1981), 88 Ill. 2d 407, 414 , 430 N.E.2d 976 .) The effect of the discovery rule, which was first adopted in Illinois in Rozny v. Marnul (1969), 43 Ill. 2d 54, 72-73 , 250 N.E.2d 656 , is to postpone the starting of the period of limitations until the injured party knows or should have known of his injury.

11982–1982

Statutes the citing opinions construe

IL § 735 ILCS 5/2-619 (10) IL § 735 ILCS 5/13-212 (4) IL § 735 ILCS 5/13-214.2 (4) IL § 735 ILCS 5/2-622 (3) IL § 740 ILCS 180/2 (3) USC § 26u.s.c.6501 (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

IL 27 (1982–2023) TN 2 (2005–2016)

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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