adequate representation requirement (Illinois) · Go Syfert
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adequate representation requirement in Illinois

26 Illinois opinions name it 1 courts 1991–2025 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.

Followed or applied (7)

CaseFollowedCited
P.J.'s Concrete Pumping Service, Inc. v. Nextel West Corp.green
illappct · 2004 · cited in 8 Illinois opinions naming this issue, 2006–2016
2 sentences

2008“The purpose of the adequate representation requirement is to ensure that all class members will receive proper, efficient, and appropriate protection of their interests in the presentation of the claim.” EJ.’s Concrete Pumping Service, Inc. v. Nextel West Corp., 345 Ill.

2008"The purpose of the adequate representation requirement is to ensure that all class members will receive proper, efficient, and appropriate protection of their interests in the presentation of the claim." P.J.'s Concrete Pumping Service, Inc. v. Nextel West Corp., 345 Ill.

68
Walczak v. Onyx Acceptance Corp.green
illappct · 2006 · cited in 6 Illinois opinions naming this issue, 2007–2016
2 sentences

2016See Uesco Industries, Inc. v. Poolman of Wisconsin, Inc., 2013 IL App (1st) 112566, ¶ 45 .) ¶ 12 “ ‘The purpose of the adequate representation requirement is to ensure that all class members will receive proper, efficient, and appropriate protection of their interests in the presentation of the claim.’ ” Walczak v. Onyx Acceptance Corp., 365 Ill.

2016See Uesco Industries, Inc. v. Poolman of Wisconsin, Inc., 2013 IL App (1st) 112566, ¶ 45 .) ¶ 12 “ ‘The purpose of the adequate representation requirement is to ensure that all class members will receive proper, efficient, and appropriate protection of their interests in the presentation of the claim.’ ” Walczak v. Onyx Acceptance Corp., 365 Ill.

66
Gordon v. Bodengreen
illappct · 1991 · cited in 13 Illinois opinions naming this issue, 2001–2025
2 sentences

2025“The adequate representation requirement of section 2-801 ensures that class members receive proper, efficient, and appropriate protection of their interests.” Bayeg, 2024 IL App (1st) 231141, ¶ 46 (citing Gordon v. Boden, 224 Ill.

2003“The purpose of the adequate representation requirement is merely to ensure that all class members will receive proper, efficient, and appropriate protection of their interests in the presentation of the claim.” Gordon, 224 Ill.

513
Uesco Industries, Inc. v. Poolman of Wisconsin, Inc.green
illappct · 2013 · cited in 2 Illinois opinions naming this issue, 2016–2016
2 sentences

2016See Uesco Industries, Inc. v. Poolman of Wisconsin, Inc., 2013 IL App (1st) 112566, ¶ 45 .) ¶ 12 “ ‘The purpose of the adequate representation requirement is to ensure that all class members will receive proper, efficient, and appropriate protection of their interests in the presentation of the claim.’ ” Walczak v. Onyx Acceptance Corp., 365 Ill.

2016See Uesco Industries, Inc. v. Poolman of Wisconsin, Inc., 2013 IL App (1st) 112566, ¶ 45 .) ¶ 12 “ ‘The purpose of the adequate representation requirement is to ensure that all class members will receive proper, efficient, and appropriate protection of their interests in the presentation of the claim.’ ” Walczak v. Onyx Acceptance Corp., 365 Ill.

22
Cruz v. Unilock Chicago, Inc.green
illappct · 2008 · cited in 2 Illinois opinions naming this issue, 2014–2015
2 sentences

2015Cruz v. Unilock Chicago, Inc., 383 Ill.

2014Cruz v. Unilock Chicago, Inc., 383 Ill.

22
Miner v. Gillette Co.green
ill · 1981 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025App. 3d 195, 203 (1991)). ¶ 59 “The test applied to determine adequacy of representation is whether the interests of those who are parties are the same as those who are not joined and whether the litigating parties fairly represent those not joined.” Miner v. Gillette Co., 87 Ill. 2d 7, 14 (1981).

11
Bayeg v. The Admiral at the Lakegreen
illappct · 2024 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025“The adequate representation requirement of section 2-801 ensures that class members receive proper, efficient, and appropriate protection of their interests.” Bayeg, 2024 IL App (1st) 231141, ¶ 46 (citing Gordon v. Boden, 224 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 (4)

CaseCitedYears
Ramirez v. Smart Corp. green
illappct · 2007
2 sentences

2016The purpose of the adequate representation requirement is merely to ensure that all class members will receive proper and efficient protection of their interests in the proceedings. - 16 - No. 1-14-3733 Ramirez, 371 Ill.

2016Id.

22016–2016
Clark v. TAP Pharmaceutical Products, Inc. green
illappct · 2003
2 sentences

2007According to Sprint, Hall's interest in pursuing her claims on behalf of a class conflicts with the interests of class members who do not want to be exposed to litigation as a result of her actions. " 'The purpose of the adequate representation requirement is merely to ensure that all class members will receive proper, efficient, and appropriate protection of their interests in the presentation of the claim.' " Clark, 343 Ill.

2007According to Sprint, Hall’s interest in pursuing her claims on behalf of a class conflicts with the interests of class members who do not want to be exposed to litigation as a result of her actions. “ ‘The purpose of the adequate representation requirement is merely to ensure that all class members will receive proper, efficient, and appropriate protection of their interests in the presentation of the claim.’ ” Clark, 343 Ill.

22007–2007
Avery v. State Farm Mutual Automobile Insurance green
illappct · 2001
2 sentences

2004Avery, 321 Ill.

2004Avery , 321 Ill.

22004–2004
Purcell & Wardrope Chartered v. Hertz Corp. green
illappct · 1988
1 sentence

1991Purcell, 175 Ill.

11991–1991

Statutes the citing opinions construe

IL § 735 ILCS 5/2-801 (13) IL § 815 ILCS 505/1 (12) IL § 815 ILCS 505/2 (10) USC § 47u.s.c.227 (6) IL § 740 ILCS 14/1 (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 26 (1991–2025) DE 6 (1996–2023) TX 3 (1990–2009) CA 2 (2008–2024) WI 2 (2006–2008)

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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