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23 Illinois opinions name it 2 courts 1919–2026 4 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 |
|---|---|---|
cluster 454679green2 sentences2018See, e.g., Eisenberg v. Gagnon, 766 F.2d 770, 787-88 (3d Cir. 1985) (“Communications to an attorney to establish a common defense strategy are privileged even though the attorney represents another client with some adverse interest.”); United States v. Bay State Ambulance & Hospital Rental Service, Inc., 874 F.2d 20, 28 (1st Cir. 1989) (quoting Eisenberg for same proposition); In re Grand Jury Subpoena Duces Tecum Dated November 16, 1974, 406 F. Supp. 381, 392 (S.D.N.Y. 1975) (fact that corporation and individual corporate officers might one day become adverse, as corporation might have claims 2017See, e.g. , Eisenberg v. Gagnon , 766 F.2d 770 , 787-88 (3d Cir. 1985) ("Communications to an attorney to establish a common defense strategy are privileged even though the attorney represents another client with some adverse interest."); United States v. Bay State Ambulance & Hospital Rental Service, Inc. , 874 F.2d 20 , 28 (1st Cir.1989) (quoting Eisenberg for same proposition); In re Grand Jury Subpoena Duces Tecum Dated November 16, 1974 , 406 F. Supp. 381 , 392 (S.D.N.Y. 1975) (fact that corporation and individual corporate officers might one day become adverse, as corporation might have | 2 | 2 |
Ambac Assurance Corporation v. Countrywide Home Loans, Inc.green2 sentences2018See, e.g., O’Boyle v. Borough of Longport, 94 A.3d 299, 317 (N.J. 2014) (adopting “the common interest rule” as “exception to waiver of confidential attorney-client communications or work product”); Ambac Assurance Corp. v. Countrywide Home Loans, Inc., 57 N.E.3d 30, 39 (N.Y. 2016) (explaining that “common-interest exception” or 1 A partial list of names include “the joint-defense doctrine, joint-defense privilege, joint- prosecutorial privilege, allied-lawyer privilege, common-interest doctrine, common-interest exception, common-interest privilege, common-interest rule, common-defense doctrin 2018See, e.g., O’Boyle v. Borough of Longport, 94 A.3d 299, 317 (N.J. 2014) (adopting “the common interest rule” as “exception to waiver of confidential attorney-client communications or work product”); Ambac Assurance Corp. v. Countrywide Home Loans, Inc., 57 N.E.3d 30, 39 (N.Y. 2016) (explaining that “common-interest exception” or 1 A partial list of names include “the joint-defense doctrine, joint-defense privilege, joint- prosecutorial privilege, allied-lawyer privilege, common-interest doctrine, common-interest exception, common-interest privilege, common-interest rule, common-defense doctrin | 2 | 2 |
Balmoral Racing Club, Inc. v. Illinois Racing Boardgreen2 sentences2002As we stated in Balmoral Racing Club, Inc. v. Illinois Racing Board , 151 Ill. 2d 367, 397 (1992), formal objections go hand in hand with formal proceedings. 2002As we stated in Balmoral Racing Club, Inc. v. Illinois Racing Board, 151 Ill. 2d 367, 397 (1992), formal objections go hand in hand with formal proceedings. | 2 | 2 |
Static Control Components, Inc. v. Lexmark International, Inc.green2 sentences2018See, e.g., Eisenberg v. Gagnon, 766 F.2d 770, 787-88 (3d Cir. 1985) (“Communications to an attorney to establish a common defense strategy are privileged even though the attorney represents another client with some adverse interest.”); United States v. Bay State Ambulance & Hospital Rental Service, Inc., 874 F.2d 20, 28 (1st Cir. 1989) (quoting Eisenberg for same proposition); In re Grand Jury Subpoena Duces Tecum Dated November 16, 1974, 406 F. Supp. 381, 392 (S.D.N.Y. 1975) (fact that corporation and individual corporate officers might one day become adverse, as corporation might have claims 2017See, e.g. , Eisenberg v. Gagnon , 766 F.2d 770 , 787-88 (3d Cir. 1985) ("Communications to an attorney to establish a common defense strategy are privileged even though the attorney represents another client with some adverse interest."); United States v. Bay State Ambulance & Hospital Rental Service, Inc. , 874 F.2d 20 , 28 (1st Cir.1989) (quoting Eisenberg for same proposition); In re Grand Jury Subpoena Duces Tecum Dated November 16, 1974 , 406 F. Supp. 381 , 392 (S.D.N.Y. 1975) (fact that corporation and individual corporate officers might one day become adverse, as corporation might have | 1 | 2 |
In Re Grand Jury Subpoena Duces Tecum Dated November 16, 1974green2 sentences2018See, e.g., Eisenberg v. Gagnon, 766 F.2d 770, 787-88 (3d Cir. 1985) (“Communications to an attorney to establish a common defense strategy are privileged even though the attorney represents another client with some adverse interest.”); United States v. Bay State Ambulance & Hospital Rental Service, Inc., 874 F.2d 20, 28 (1st Cir. 1989) (quoting Eisenberg for same proposition); In re Grand Jury Subpoena Duces Tecum Dated November 16, 1974, 406 F. Supp. 381, 392 (S.D.N.Y. 1975) (fact that corporation and individual corporate officers might one day become adverse, as corporation might have claims 2017See, e.g. , Eisenberg v. Gagnon , 766 F.2d 770 , 787-88 (3d Cir. 1985) ("Communications to an attorney to establish a common defense strategy are privileged even though the attorney represents another client with some adverse interest."); United States v. Bay State Ambulance & Hospital Rental Service, Inc. , 874 F.2d 20 , 28 (1st Cir.1989) (quoting Eisenberg for same proposition); In re Grand Jury Subpoena Duces Tecum Dated November 16, 1974 , 406 F. Supp. 381 , 392 (S.D.N.Y. 1975) (fact that corporation and individual corporate officers might one day become adverse, as corporation might have | 1 | 2 |
cluster 522863green2 sentences2018See, e.g., Eisenberg v. Gagnon, 766 F.2d 770, 787-88 (3d Cir. 1985) (“Communications to an attorney to establish a common defense strategy are privileged even though the attorney represents another client with some adverse interest.”); United States v. Bay State Ambulance & Hospital Rental Service, Inc., 874 F.2d 20, 28 (1st Cir. 1989) (quoting Eisenberg for same proposition); In re Grand Jury Subpoena Duces Tecum Dated November 16, 1974, 406 F. Supp. 381, 392 (S.D.N.Y. 1975) (fact that corporation and individual corporate officers might one day become adverse, as corporation might have claims 2017See, e.g. , Eisenberg v. Gagnon , 766 F.2d 770 , 787-88 (3d Cir. 1985) ("Communications to an attorney to establish a common defense strategy are privileged even though the attorney represents another client with some adverse interest."); United States v. Bay State Ambulance & Hospital Rental Service, Inc. , 874 F.2d 20 , 28 (1st Cir.1989) (quoting Eisenberg for same proposition); In re Grand Jury Subpoena Duces Tecum Dated November 16, 1974 , 406 F. Supp. 381 , 392 (S.D.N.Y. 1975) (fact that corporation and individual corporate officers might one day become adverse, as corporation might have | 1 | 2 |
United States v. Robert McPartlingreen2 sentences2018Colo. 2007) (some adversity among parties does not defeat common-interest doctrine). ¶ 82 Notably, when the Supreme Court proposed the codification of the common-interest exception (though rejected by Congress in favor of no codified privilege), committee comments suggested the rule applied when clients had “[s]ome interests in common” and not when “there is [n]o common interest to be promoted by a joint consultation.” (Emphasis added and internal quotation marks omitted.) McPartlin, 595 F.2d at 1336 . 2018For example, in United States v. McPartlin, 595 F.2d 1321, 1336 (7th Cir. 1979), the court held that a party was entitled to the protection of the attorney-client privilege when his statements were made in confidence to an attorney for a codefendant for a common purpose related to both defenses. | 1 | 2 |
People v. Millergreen1 sentence2026Section 2-107.1(a-5)(2) of the Code states that a hearing on a petition for administration of psychotropic medicine “shall be separate from a judicial proceeding held to determine whether a person is subject to involuntary admission but may be heard immediately preceding or following such a judicial proceeding and may be heard by the same trier of fact or law as in that judicial proceeding.” 405 ILCS 5/2-107.1(a-5)(2) (West 2024); see In re Barbara H., 183 Ill. 2d 482, 498 (1998) (“The joint hearing was in direct violation of section 2- - 16 - 107.1(a)(2) of the Mental Health Code.”); see also | 1 | 1 |
People v. Barbara H.green1 sentence2026Section 2-107.1(a-5)(2) of the Code states that a hearing on a petition for administration of psychotropic medicine “shall be separate from a judicial proceeding held to determine whether a person is subject to involuntary admission but may be heard immediately preceding or following such a judicial proceeding and may be heard by the same trier of fact or law as in that judicial proceeding.” 405 ILCS 5/2-107.1(a-5)(2) (West 2024); see In re Barbara H., 183 Ill. 2d 482, 498 (1998) (“The joint hearing was in direct violation of section 2- - 16 - 107.1(a)(2) of the Mental Health Code.”); see also | 1 | 1 |
People v. Smithgreen1 sentence2025See People v. Smith, 259 Ill. | 1 | 1 |
Harris v. Allied American Insurancegreen1 sentence2022See Harris v. Allied American Insurance Co., 152 Ill. | 1 | 1 |
TOBACCOVILLE USA, INC. v. McMastergreen1 sentence2018See, e.g., O’Boyle v. Borough of Longport, 94 A.3d 299, 317 (N.J. 2014) (adopting “the common interest rule” as “exception to waiver of confidential attorney-client communications or work product”); Ambac Assurance Corp. v. Countrywide Home Loans, Inc., 57 N.E.3d 30, 39 (N.Y. 2016) (explaining that “common-interest exception” or 1 A partial list of names include “the joint-defense doctrine, joint-defense privilege, joint- prosecutorial privilege, allied-lawyer privilege, common-interest doctrine, common-interest exception, common-interest privilege, common-interest rule, common-defense doctrin | 1 | 1 |
Arizona Independent Redistricting Commission v. Fieldsgreen1 sentence2018See, e.g., O’Boyle v. Borough of Longport, 94 A.3d 299, 317 (N.J. 2014) (adopting “the common interest rule” as “exception to waiver of confidential attorney-client communications or work product”); Ambac Assurance Corp. v. Countrywide Home Loans, Inc., 57 N.E.3d 30, 39 (N.Y. 2016) (explaining that “common-interest exception” or 1 A partial list of names include “the joint-defense doctrine, joint-defense privilege, joint- prosecutorial privilege, allied-lawyer privilege, common-interest doctrine, common-interest exception, common-interest privilege, common-interest rule, common-defense doctrin | 1 | 1 |
Martin O'boyle v. Borough of Longportgreen1 sentence2018See, e.g., O’Boyle v. Borough of Longport, 94 A.3d 299, 317 (N.J. 2014) (adopting “the common interest rule” as “exception to waiver of confidential attorney-client communications or work product”); Ambac Assurance Corp. v. Countrywide Home Loans, Inc., 57 N.E.3d 30, 39 (N.Y. 2016) (explaining that “common-interest exception” or 1 A partial list of names include “the joint-defense doctrine, joint-defense privilege, joint- prosecutorial privilege, allied-lawyer privilege, common-interest doctrine, common-interest exception, common-interest privilege, common-interest rule, common-defense doctrin | 1 | 1 |
Boyd v. Comdata Network, Inc.green1 sentence2017Presiding Justice Burke and Justice McBride concurred in the judgment and opinion. 1 A partial list of names include "the joint-defense doctrine, joint-defense privilege, joint-prosecutorial privilege, allied-lawyer privilege, common-interest doctrine, common-interest exception, common-interest privilege, common-interest rule, common-defense doctrine, pooled-information privilege, common-purpose theory, community-of-interest doctrine, joint-client privilege, joint-client doctrine, common-interest exception to waiver, and shared-confidentiality privilege." Id. 2 A small sample of these decision | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
People Ex Rel. Klaeren v. Village of Lisle
green
2 sentences2021It ultimately held that “because the joint hearing included a special use petition, due process required that interested parties be afforded the right to cross-examine witnesses.” Id. 2004Pertinently, however, it did note that, "[w]hile time limits may be necessary in certain circumstances, the two-minute time limit imposed here would have been clearly improper had the proceedings complied with the due process requisite of cross-examination for interested parties." Klaeren II , 202 Ill. 2d at 188 . | 3 | 2004–2021 |
Brody v. Hess
green
2 sentences2016Id. at 404 . 2015Id. at 404 . | 3 | 1999–2016 |
Apprendi v. New Jersey
green
2 sentences2002Defendant appeals, arguing (1) he was denied a fair trial because the State improperly used other-crimes evidence to show propensity to commit crimes, (2) the prosecutor made improper statements in his closing argument, and (3) his enhanced sentence based on his habitual criminal status is unconstitutional under Apprendi v. New Jersey, 530 U.S. 466 , 147 L. 2002Defendant appeals, arguing (1) he was denied a fair trial because the State improperly used other-crimes evidence to show propensity to commit crimes, (2) the prosecutor made improper statements in his closing argument, and (3) his enhanced sentence based on his habitual criminal status is unconstitutional under Apprendi v. New Jersey, 530 U.S. 466 , 147 L. | 2 | 2002–2002 |
Palos Community Hospital v. Humana Insurance Co., Inc.
green
1 sentence2025It noted that on or about May 6, 2024, plaintiff and third-party defendants entered into a “joint defense agreement.” It added, “The joint defense agreement and the motion for substitution of Judge are certainly separate but intertwined issues.” Generally, “a joint defense agreement is entered into by and between co-defendants in litigation where their legal interests, defenses, strategies, et cetera, align.” Counsel for plaintiff and third-party defendants had engaged in correspondence regarding the motion to substitute, and plaintiff’s counsel offered “to ghostwrite either the motion or the | 1 | 2025–2025 |
Village of Kirkland v. Kirkland Properties Holdings Co.
green
1 sentence2025It added, “[S]uch a motion is granted when properly made.” A -7- 2025 IL App (2d) 240596 court “has no discretion to deny the motion.” The trial court noted that plaintiff secured Burney to represent third-party defendants, and, as part of that legal relationship, plaintiff and third-party defendants entered into a joint defense agreement. | 1 | 2025–2025 |
Shamrock Chicago Corp. v. Wroblewski
green
1 sentence2020If the trial court's factual findings are not in dispute or if those findings are consistent with the manifest weight of the evidence, we review the contempt order for an abuse of discretion, considering the relevant facts.” Shamrock Chicago Corp. v. Wroblewski, 2019 IL App (1st) 182354, ¶ 29 . - 19 - 2020 IL App (2d) 180726 The deference embodied in the joint standard is consistent with the typical role of each individual standard. | 1 | 2020–2020 |
In re Marriage of Montgomery
green
1 sentence2020If the trial court's factual findings are not in dispute or if those findings are consistent with the manifest weight of the evidence, we review the contempt order for an abuse of discretion, considering the relevant facts.” Shamrock Chicago Corp. v. Wroblewski, 2019 IL App (1st) 182354, ¶ 29 . - 19 - 2020 IL App (2d) 180726 The deference embodied in the joint standard is consistent with the typical role of each individual standard. | 1 | 2020–2020 |
Adkins Energy, LLC v. Delta-T Corp.
green
1 sentence2017Presiding Justice Burke and Justice McBride concurred in the judgment and opinion. 1 A partial list of names include "the joint-defense doctrine, joint-defense privilege, joint-prosecutorial privilege, allied-lawyer privilege, common-interest doctrine, common-interest exception, common-interest privilege, common-interest rule, common-defense doctrine, pooled-information privilege, common-purpose theory, community-of-interest doctrine, joint-client privilege, joint-client doctrine, common-interest exception to waiver, and shared-confidentiality privilege." Id. 2 A small sample of these decision | 1 | 2017–2017 |
Ken's Foods, Inc. v. Ken's Steak House, Inc.
green
1 sentence2017Presiding Justice Burke and Justice McBride concurred in the judgment and opinion. 1 A partial list of names include "the joint-defense doctrine, joint-defense privilege, joint-prosecutorial privilege, allied-lawyer privilege, common-interest doctrine, common-interest exception, common-interest privilege, common-interest rule, common-defense doctrine, pooled-information privilege, common-purpose theory, community-of-interest doctrine, joint-client privilege, joint-client doctrine, common-interest exception to waiver, and shared-confidentiality privilege." Id. 2 A small sample of these decision | 1 | 2017–2017 |
Schaeffler v. United States
green
1 sentence2017Presiding Justice Burke and Justice McBride concurred in the judgment and opinion. 1 A partial list of names include "the joint-defense doctrine, joint-defense privilege, joint-prosecutorial privilege, allied-lawyer privilege, common-interest doctrine, common-interest exception, common-interest privilege, common-interest rule, common-defense doctrine, pooled-information privilege, common-purpose theory, community-of-interest doctrine, joint-client privilege, joint-client doctrine, common-interest exception to waiver, and shared-confidentiality privilege." Id. 2 A small sample of these decision | 1 | 2017–2017 |
United States v. BDO Seidman, LLP
green
1 sentence2017Presiding Justice Burke and Justice McBride concurred in the judgment and opinion. 1 A partial list of names include "the joint-defense doctrine, joint-defense privilege, joint-prosecutorial privilege, allied-lawyer privilege, common-interest doctrine, common-interest exception, common-interest privilege, common-interest rule, common-defense doctrine, pooled-information privilege, common-purpose theory, community-of-interest doctrine, joint-client privilege, joint-client doctrine, common-interest exception to waiver, and shared-confidentiality privilege." Id. 2 A small sample of these decision | 1 | 2017–2017 |
Davis v. Weiskopf
green
1 sentence1989(Davis v. Weiskopf, 108 Ill. | 1 | 1989–1989 |
Galayda v. Penman
green
1 sentence1982(Galayda v. Penman (1980), 80 Ill. | 1 | 1982–1982 |
People v. Banks
neutral
1 sentence1969People v. Dolgin, 415 Ill 434, 114 NE2d 389 ; People v. Banks, 103 Ill App2d 180, 243 NE2d 669 . | 1 | 1969–1969 |
People v. Dolgin
green
1 sentence1969People v. Dolgin, 415 Ill 434, 114 NE2d 389 ; People v. Banks, 103 Ill App2d 180, 243 NE2d 669 . | 1 | 1969–1969 |
| The People v. Earl green | 1 | 1967–1967 |
| Schofield v. Thomas neutral | 1 | 1936–1936 |
| De Grasse v. Verona Mining Co. green | 1 | 1934–1934 |
| Merle v. Beifeld neutral | 1 | 1919–1919 |
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.