fact-based inquiry (Illinois) · Go Syfert
← Illinois issues

fact-based inquiry in Illinois

24 Illinois opinions name it 2 courts 2002–2026 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 (8)

CaseFollowedCited
Smith v. Airoom, Inc.green
ill · 1986 · cited in 5 Illinois opinions naming this issue, 2016–2026
2 sentences

2026Smith v. Airoom, Inc., 114 Ill. 2d 209, 220-21 (1986).

2026Smith, 114 Ill. 2d at 220-21 .

35
PGA Tour, Inc. v. Martingreen
scotus · 2001 · cited in 2 Illinois opinions naming this issue, 2020–2020
2 sentences

2020This is a fact-based inquiry (see PGA Tour, Inc. v. Martin, 532 U.S. 661, 673 (2001)), but defendant argues that there was no inquiry before the trial court permitted the dog.

2020This is a fact-based inquiry (see PGA Tour, Inc. v. Martin, 532 U.S. 661, 673 (2001)), but defendant argues that there was no inquiry before the trial court permitted the dog.

22
Seufert v. Merck Sharp & Dohme Corp.green
casd · 2016 · cited in 2 Illinois opinions naming this issue, 2019–2019
2 sentences

2019Wash. 2014) ("the clear evidence standard is a fact based inquiry that depends on the express type of warning at issue and the particular facts of each case"); Seufert v. Merck Sharp & Dohme Corp. , 187 F.Supp.3d 1163 , 1170 (S.D.

2019Wash. 2014) (“the clear evidence standard is a fact based inquiry that depends on the express type of warning at issue and the particular facts of each case”); Seufert v. Merck Sharp & Dohme Corp., 187 F. Supp. 3d 1163, 1170 (S.D.

12
Lofton v. McNeil Consumer & Specialty Pharmaceuticalsgreen
txnd · 2010 · cited in 2 Illinois opinions naming this issue, 2019–2019
2 sentences

2019Cal. 2016) (it is a "fact specific inquiry dependent on the particular warning at issue in each case"); Lofton v. McNeil Consumer & Specialty Pharmaceuticals , 682 F.Supp.2d 662 , 677 (N.D.

2019Cal. 2016) (it is a “fact specific inquiry dependent on the particular warning at issue in each case”); Lofton v. McNeil Consumer & Specialty Pharmaceuticals, 682 F. Supp. 2d 662, 677 (N.D.

12
People v. Gandygreen
illappct · 1992 · cited in 2 Illinois opinions naming this issue, 2004–2004
2 sentences

2004The State highlights that the Pinkonsly court cited to the Fourth District's opinion in People v. Gandy , which said where "the section 2-1401 petition is prepared pro se and alleges a deprivation of constitutional rights cognizable under the Post-Conviction Hearing Act, the trial court is to treat it as such." Gandy , 227 Ill.

2004The State highlights that the Pinkonsly court cited to the Fourth District's opinion in People v. Gandy , which said where "the section 2-1401 petition is prepared pro se and alleges a deprivation of constitutional rights cognizable under the Post-Conviction Hearing Act, the trial court is to treat it as such." Gandy, 227 Ill.App.3d 112, 139 , 169 Ill.Dec. 165 , 591 N.E.2d 45, 64 (1992).

12
Foutch v. O'BRYANTgreen
ill · 1984 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026See Foutch v. O’Bryant, 99 Ill. 2d 389, 391-92 (1984). 7 No. 1-25-1989 ¶ 22 Culver’s final claim is that the circuit court substantively erred by dismissing her amended motion to vacate because she sufficiently alleged a valid fact-based challenge to the default order. ¶ 23 To establish a fact-based challenge to a default order via a section 2-1401 petition, a party must demonstrate three elements: (1) they had a meritorious defense to the underlying claim, (2) they acted diligently in presenting that defense, and (3) they acted diligently in filing their section 2-1401 petition.

11
Harris Bank, N.A. v. Harrisgreen
illappct · 2015 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023See Harris Bank, 2015 IL App (1st) 133017, ¶ 60 (finding that section 2-1401 petition did not raise a purely legal error where the plaintiff presented fact-dependent challenges to the circuit court’s judgment). ¶ 30 As noted, where a section 2-1401 petition raises a fact-dependent challenge, the petitioner is required to allege facts establishing (1) the existence of a meritorious defense or claim, (2) due diligence in presenting the defense or claim to the circuit court in the original action, and (3) due diligence in filing the section 2-1401 petition.

11
AFM Messenger Service, Inc. v. Department of Employment Securitygreen
ill · 2001 · cited in 1 Illinois opinions naming this issue, 2002–2002
2 sentences

2002See AFM Messenger Service, Inc. v. Department of Employment Security, 198 Ill. 2d 380, 391-92 , 763 N.E.2d 272 (2001) (clearly erroneous standard applied to Department’s decision that employees were not independent contractors as that term is defined in section 212 of the Act).

2002See AFM Messenger Service, Inc. v. Department of Employment Security, 198 Ill. 2d 380, 391-92 , 763 N.E.2d 272 (2001) (clearly erroneous standard applied to Department’s decision that employees were not independent contractors as that term is defined in section 212 of the Act).

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 (8)

CaseCitedYears
Warren County Soil and Water Conservation District v. Walters green
ill · 2015
2 sentences

2016Warren County, 2015 IL 117783, ¶ 51 ; Smith, 114 Ill. 2d at 225 .

2016Warren County, 2015 IL 117783, ¶ 51 ; Smith, 114 Ill. 2d at 225 .

32016–2016
People v. Johnson green
illappct · 2007
2 sentences

2015Id. at 780 .

2015Id. at 780 .

32015–2015
People v. Crowder green
illappct · 2018
2 sentences

2021In Crowder, 2018 IL App (1st) 161226, ¶ 29 , the appellate court found self-defense is available against weapons possession charges “when an immediate, greater evil threatens a person who initiated no violence and had no other recourse.” ¶ 61 Ultimately, the case law cited by defendant confirms that deciding whether self- defense is an available defense is a fact-based inquiry driven by considering not only the charges - 13 - but also the specific factual circumstances surrounding the alleged commission of the offenses.

2021In Crowder, 2018 IL App (1st) 161226, ¶ 29 , the appellate court found self-defense is available against weapons possession charges “when an immediate, greater evil threatens a person who initiated no violence and had no other recourse.” ¶ 61 Ultimately, the case law cited by defendant confirms that deciding whether self-defense is an available defense is a fact-based inquiry driven by considering not only the charges but also the specific factual circumstances surrounding the alleged commission of the offenses.

22021–2021
Department of Central Management Services v. Illinois Labor Relations Board, State Panel green
illappct · 2010
2 sentences

2014The Board concluded that the ALJ's determination 9 No. 1-12-3426 that the ALJs were managerial employees was supported by the evidence and consistent with the appellate court's analysis in Department of Central Management Services, 406 Ill.

2014The Board concluded that the ALJ’s determination that the ALJs were managerial employees was supported by the evidence and consistent with the appellate court’s analysis in Department of Central Management Services, 406 Ill.

22014–2014
People Ex Rel. Palmer v. Twomey green
ill · 1973
2 sentences

2004Palmer v. Twomey , 53 Ill. 2d 479 , 292 N.E.2d 379 (1973), actually require that petitioner's motion be treated as a postconviction petition because the motion presented a constitutional, as opposed to a fact-based claim.

2004Palmer v. Twomey , 53 Ill. 2d 479 , 292 N.E.2d 379 (1973), actually require that petitioner's motion be treated as a postconviction petition because the motion presented a constitutional, as opposed to a fact-based claim.

22004–2004
Lutheran Church of Good Shepherd of Bourbonnais v. Department of Revenue green
illappct · 2000
2 sentences

2002Lutheran Church, 316 Ill.

2002Lutheran Church, 316 Ill.

22002–2002
Rehfield v. Diocese of Joliet neutral
illappct · 2020
1 sentence

2021As to count I, the trial court determined that the amended complaint failed to state a claim for retaliatory discharge because plaintiff was employed pursuant to a contract and “[c]ommon law retaliatory discharge claims may only be asserted by employees terminable at will.” The trial court further determined that it must abstain from deciding both of plaintiff’s claims in accordance with the doctrine of ecclesiastic abstention. ¶ 17 Plaintiff appealed, and the appellate court affirmed the trial court’s dismissal of the first amended complaint with prejudice. 2019 IL App (3d) 180354 .

12021–2021
American Federation of State v. Illinois State Labor Relations Board green
illappct · 2002
1 sentence

2004American Federation of State, County & Municipal Employees v. Illinois State Labor Relations Board, 333 Ill.

12004–2004

Statutes the citing opinions construe

IL § 735 ILCS 5/2-1401 (8) IL § 5 ILCS 315/3 (3) IL § 705 ILCS 405/1-1 (3) IL § 705 ILCS 405/1-5 (3) IL § 705 ILCS 405/5-605 (3) IL § 720 ILCS 5/17-32 (3) IL § 720 ILCS 5/18-5 (3) IL § 720 ILCS 5/31-6 (3) IL § 725 ILCS 5/111-3 (3) IL § 730 ILCS 5/5-4.5-30 (3) IL § 735 ILCS 5/2-615 (3) IL § 735 ILCS 5/2-619 (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

CT 65 (1994–2026) CA 29 (1991–2026) IL 24 (2002–2026) NY 20 (1994–2026) PA 16 (1997–2026) OR 14 (1997–2025) TX 12 (2010–2022) DC 12 (1991–2021) OH 11 (1999–2018) IA 10 (2018–2022) NM 8 (1994–2024) VA 7 (2002–2026) MA 7 (1997–2023) WA 7 (2007–2019) NC 6 (2012–2020) CO 6 (2010–2026) FL 6 (1996–2015) MN 6 (1990–2025) MI 5 (2017–2022) UT 5 (2015–2023) KS 4 (2007–2023) SC 4 (2008–2017) LA 3 (1995–2006) DE 3 (2020–2025) MD 3 (2008–2010) GA 3 (2016–2025) ME 2 (1995–2020) OK 2 (1990–2018) NE 2 (2019–2019) NJ 2 (1987–2001) AR 2 (2011–2011) MO 2 (2012–2016)

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.

← Caselaw search · G Cite Topics · Brief Check