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21 Illinois opinions name it 2 courts 2015–2026 12 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 |
|---|---|---|
King v. First Capital Financial Services Corp.green2 sentences2023King v. First Capital Financial Services Corp., 215 Ill. 2d 1, 12 (2005). 2018King v. First Capital Financial Services Corp. , 215 Ill. 2d 1 , 12, 293 Ill.Dec. 657 , 828 N.E.2d 1155 (2005). | 2 | 3 |
Van Meter v. Darien Park Dist.green1 sentence2025See 735 ILCS 5/2-619(a) (West 2022); Van Meter v. Darien Park District, 207 Ill. 2d 359, 367 (2003). | 1 | 1 |
Van Duyn v. Smithgreen1 sentence2024App. 3d 523, 538 , 527 N.E.2d 1005, 1015 (1988) (“Only well pleaded facts are admitted by a section 2-615 motion to dismiss and it is commonly understood that attached exhibits supercede any inconsistent allegations of a complaint.”). ¶ 42 A section 2-619 motion to dismiss (735 ILCS 5/2-619 (West 2020)) “admits the sufficiency of the complaint but asserts a defense outside of the complaint that defeats it.” O’Connell v. County of Cook, 2022 IL 127527, ¶ 19 , 210 N.E.3d 1251 . | 1 | 1 |
Marshall v. Burger King Corp.green2 sentences2022“In reviewing the sufficiency of a complaint, we accept as true all well-pleaded facts and all reasonable inferences that may be drawn from those facts,” and we “construe the allegations in the complaint in the light most favorable to the plaintiff.” Marshall v. Burger King Corp., 222 Ill. 2d 422, 429 (2006). “[A] cause of action should not be dismissed pursuant to section 2-615 unless it is clearly apparent that no set of facts can be proved that would entitle the plaintiff to recovery.” Id. ¶ 19 A motion to dismiss under section 2-619 (735 ILCS 5/2-619 (West 2018)) admits the sufficiency of 2022“In reviewing the sufficiency of a complaint, we accept as true all well-pleaded facts and all reasonable inferences that may be drawn from those facts,” and we “construe the allegations in the complaint in the light most favorable to the plaintiff.” Marshall v. Burger King Corp., 222 Ill. 2d 422, 429 (2006). “[A] cause of action should not be dismissed pursuant to section 2-615 unless it is clearly apparent that no set of facts can be proved that would entitle the plaintiff to recovery.” Id. ¶ 19 A motion to dismiss under section 2-619 (735 ILCS 5/2-619 (West 2018)) admits the sufficiency of | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Patrick Engineering, Inc. v. The City of Naperville
green
2 sentences2022Patrick Engineering, Inc. v. City of Naperville, 2012 IL 113148, ¶ 31 . 2022Patrick Engineering, Inc., 2012 IL 113148, ¶ 31 . | 12 | 2015–2022 |
O'Connell v. County of Cook
green
2 sentences2026Plaintiff further maintains that the court erred in dismissing her claims against the City and Doyle with prejudice and denying her leave to amend her pleading. ¶ 28 A. Dismissals Under Section 2-619 ¶ 29 “A motion to dismiss under section 2-619 [citation] admits the sufficiency of the complaint but asserts a defense outside of the complaint that defeats it.” O’Connell v. County of Cook, 2022 IL 127527, ¶ 19 . 2024App. 3d 523, 538 , 527 N.E.2d 1005, 1015 (1988) (“Only well pleaded facts are admitted by a section 2-615 motion to dismiss and it is commonly understood that attached exhibits supercede any inconsistent allegations of a complaint.”). ¶ 42 A section 2-619 motion to dismiss (735 ILCS 5/2-619 (West 2020)) “admits the sufficiency of the complaint but asserts a defense outside of the complaint that defeats it.” O’Connell v. County of Cook, 2022 IL 127527, ¶ 19 , 210 N.E.3d 1251 . | 3 | 2024–2026 |
Mercado v. S&C Electric Co.
green
1 sentence2026Under section 2-619(a)(9) of the Code, the trial court may involuntarily dismiss a claim when it “is barred by other affirmative matter avoiding the legal effect of or defeating the claim.” 735 ILCS 5/2-619(a)(9) (West 2024). “ ‘Affirmative matter’ encompasses any defense other than a denial of the essential allegations of the plaintiff’s claim.” Mercado v. S&C Electric Co., 2025 IL 129526, ¶ 19 . | 1 | 2026–2026 |
Rehfield v. Diocese of Joliet
green
2 sentences2024“A court should not dismiss a complaint pursuant to [section 2-615] unless it is clearly apparent that no set of facts can be proved that would entitle the plaintiff to recovery.” Rehfield v. Diocese of Joliet, 2021 IL 125656, ¶ 20 , 182 N.E.3d 123 . ¶ 39 A section 2-619 motion to dismiss (735 ILCS 5/2-619 (West 2020)) “admits the sufficiency of the complaint but asserts a defense outside of the complaint that defeats it.” O’Connell v. County of Cook, 2022 IL 127527, ¶ 19 , 210 N.E.3d 1251 . 2024“A court should not dismiss a complaint pursuant to [section 2-615] unless it is clearly apparent that no set of facts can be proved that would entitle the plaintiff to recovery.” Rehfield v. Diocese of Joliet, 2021 IL 125656, ¶ 20 , 182 N.E.3d 123 . ¶ 39 A section 2-619 motion to dismiss (735 ILCS 5/2-619 (West 2020)) “admits the sufficiency of the complaint but asserts a defense outside of the complaint that defeats it.” O’Connell v. County of Cook, 2022 IL 127527, ¶ 19 , 210 N.E.3d 1251 . | 1 | 2024–2024 |
Strauss v. City of Chicago
green
2 sentences2024“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.” (Internal quotation marks omitted.) Strauss v. City of Chicago, 2022 IL 127149 , - 12 - ¶ 54, 215 N.E.3d 87 . ¶ 40 Relevant to this appeal, section 2-619(a)(6) provides for involuntary dismissal if “the claim set forth in the plaintiff’s pleading has been released, satisfied of record, or discharged in bankruptcy.” 735 ILCS 5/2-619(a)(6) (West 2020). 2024“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.” (Internal quotation marks omitted.) Strauss v. City of Chicago, 2022 IL 127149 , - 12 - ¶ 54, 215 N.E.3d 87 . ¶ 40 Relevant to this appeal, section 2-619(a)(6) provides for involuntary dismissal if “the claim set forth in the plaintiff’s pleading has been released, satisfied of record, or discharged in bankruptcy.” 735 ILCS 5/2-619(a)(6) (West 2020). | 1 | 2024–2024 |
Reynolds v. Jimmy John's Enterprises, LLC
green
1 sentence2023“In ruling on a section 2-615 motion, the court only considers (1) those facts apparent from the face of the pleadings, (2) matters subject to judicial notice, and (3) judicial admissions in the record.” Reynolds v. Jimmy John’s Enterprises, LLC, 2013 IL App (4th) 120139, ¶ 25 . ¶ 15 A section 2-619 motion to dismiss admits the sufficiency of the complaint but asserts a defense outside the complaint that defeats it. | 1 | 2023–2023 |
Bedin v. Northwestern Memorial Hospital
green
1 sentence2021Bedin v. Northwestern Memorial Hospital, 2021 IL App (1st) 190723, ¶ 38 . | 1 | 2021–2021 |
Skaperdas v. Country Casualty Insurance Company
green
2 sentences2021Skaperdas v. Country Casualty Insurance Co., 2015 IL 117021, ¶ 14 , 28 N.E.3d 747 . 2021Skaperdas v. Country Casualty Insurance Co., 2015 IL 117021, ¶ 14 , 28 N.E.3d 747 . | 1 | 2021–2021 |
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.