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18 Illinois opinions name it 1 courts 1988–2026 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.
| Case | Followed | Cited |
|---|---|---|
Smagala v. Owengreen2 sentences2015Cf. Dwelle, 839 So. 2d at 901 ("the lower court erroneously relied on [the child's] 7 State Farm argues that Illinois courts have rejected the reasonable expectations doctrine and cites in support Smagla v. Owen, 307 Ill. 2015The reasonable expectations test is "used as a tool of construction in assessing the intent of the parties when a contract is ambiguous." Smagla, 307 Ill. | 5 | 6 |
El Rincon Supportive Services Organization, Inc. v. First Nonprofit Mutual Insurancegreen2 sentences2011See, e.g., El Rincon Supportive Services Organization, Inc. v. First Nonprofit Mutual Insurance Co., 346 Ill.App.3d 96, 106 , 281 Ill.Dec. 128 , 803 N.E.2d 532 (2004); Smagala, 307 Ill.App.3d at 219 , 240 Ill. 2011See, e.g., El Rincon Supportive Services Organization, Inc. v. First Nonprofit Mutual Insurance Co., 346 Ill.App.3d 96, 106 , 281 Ill.Dec. 128 , 803 N.E.2d 532 (2004); Smagala, 307 Ill.App.3d at 219 , 240 Ill. | 2 | 2 |
General Insurance Co. of America v. Robert B. McManus, Inc.green2 sentences1999See General Insurance Co., 272 Ill. 1999See General Insurance Co. , 272 Ill. | 2 | 2 |
Pioneer Ins. Co. v. Alliance Ins. Co.green2 sentences2011We are not warranted, under the cloak of construction, in making a new contract for the parties.'" Rich, 226 Ill.2d at 381 , 314 Ill.Dec. 795 , 875 N.E.2d 1082 (quoting Pioneer Life Insurance Co. v. Alliance Life Insurance Co., 374 Ill. 576, 590 , 30 N.E.2d 66 (1940)). 2011We are not warranted, under the cloak of construction, in making a new contract for the parties.'" Rich, 226 Ill.2d at 381 , 314 Ill.Dec. 795 , 875 N.E.2d 1082 (quoting Pioneer Life Insurance Co. v. Alliance Life Insurance Co., 374 Ill. 576, 590 , 30 N.E.2d 66 (1940)). | 1 | 2 |
Northern Trust Co. v. VIII South Michigan Associatesgreen1 sentence2026Northern Trust Co. v. VIII South Michigan Associates, 276 Ill. | 1 | 1 |
Landmark Insurance Company v. NIP Groupgreen1 sentence2025Co. v. NIP Group Inc., 2011 IL App (1st) 101155, ¶ 26 (remarking that “the status of the reasonable-expectations doctrine in Illinois is, at best, unclear.”). ¶ 67 This court’s precedent indicates that reasonable expectations can be taken into account only when there is an ambiguity in the policy language, but the courts are otherwise bound to apply the unambiguous language of the policy. | 1 | 1 |
State Farm Mutual Automobile Insurance Co. v. Progressive Northern Insurance Co.green1 sentence2025The test is not used when a study of the policy provisions would have negated those expectations.” State Farm Mutual Auto Insurance Co. v. Progressive Northern Insurance Co., 2015 IL App (1st) 140447, ¶ 109, n. 7 . | 1 | 1 |
Dwelle v. State Farm Mutual Automobile Insurance Companygreen1 sentence2015Cf. Dwelle, 839 So. 2d at 901 ("the lower court erroneously relied on [the child's] 7 State Farm argues that Illinois courts have rejected the reasonable expectations doctrine and cites in support Smagla v. Owen, 307 Ill. | 1 | 1 |
Werner Industries, Inc. v. First State Insurancegreen1 sentence2011Under this doctrine, “if an insured’s ‘reasonable expectations’ contravene the plain meaning of a policy, even its plain meaning can be overcome.” Voorhees, 607 A.2d at 1260 (quoting Werner Industries v. First State Insurance Co., 548 A.2d 188, 191 (N.J. 1988). | 1 | 1 |
Zacarias v. Allstate Insurancegreen1 sentence2011Specifically, New Jersey applies what is known as the “doctrine of reasonable expectations.” Zacarias v. Allstate Insurance Co., 775 A.2d 1262, 1265 (N.J. 2001). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Support Council of District 39 v. Illinois Educational Labor Relations Board
green
2 sentences2015Wilmette, 366 Ill. 2015Wilmette, 366 Ill. | 3 | 2008–2015 |
Continental Casualty Company v. Howard Hoffman and Associates
green
2 sentences2025Under that doctrine, “the objectively reasonable expectations of all applicants and intended beneficiaries regarding the terms of insurance contracts will be honored even though painstaking study of the policy provisions would have negated those expectations.” Continental Casualty Co. v. Howard Hoffman and Associates, 2011 IL App (1st) 100957, ¶ 76 . 2022Howard Hoffman noted that some Illinois courts have rejected the doctrine while others seem to have accepted it, terming the doctrine’s application in Illinois “an open question.” Howard Hoffman, 2011 IL App (1st) 100957, ¶¶ 77-78 . ¶ 68 Medline denies raising the reasonable expectations doctrine. | 2 | 2022–2025 |
Rich v. Principal Life Insurance
green
2 sentences2011We are not warranted, under the cloak of construction, in making a new contract for the parties.'" Rich, 226 Ill.2d at 381 , 314 Ill.Dec. 795 , 875 N.E.2d 1082 (quoting Pioneer Life Insurance Co. v. Alliance Life Insurance Co., 374 Ill. 576, 590 , 30 N.E.2d 66 (1940)). 2011We are not warranted, under the cloak of construction, in making a new contract for the parties.'" Rich, 226 Ill.2d at 381 , 314 Ill.Dec. 795 , 875 N.E.2d 1082 (quoting Pioneer Life Insurance Co. v. Alliance Life Insurance Co., 374 Ill. 576, 590 , 30 N.E.2d 66 (1940)). | 2 | 2011–2011 |
Hoglund v. State Farm Mutual Automobile Insurance
green
2 sentences1996In Hoglund v. State Farm Mutual Automobile Insurance Co., 148 Ill. 2d 272 , 592 N.E.2d 1031 (1992), the Illinois Supreme Court voided express policy language under the reasonable expectations doctrine. 1996In Hoglund v. State Farm Mutual Automobile Insurance Co., 148 Ill. 2d 272 , 592 N.E.2d 1031 (1992), the Illinois Supreme Court voided express policy language under the reasonable expectations doctrine. | 2 | 1996–1996 |
Crum & Forster Managers Corp. v. Resolution Trust Corp.
green
1 sentence2025Rather, “[i]f the words in the policy are plain and unambiguous, the court will afford them their plain, ordinary meaning and will apply them as written.” Id. ¶ 66 To the extent plaintiffs invoke the reasonable expectations doctrine, this court has questioned its viability. | 1 | 2025–2025 |
Crawford Laboratories, Inc. v. St. Paul Insurance
green
2 sentences2011Paul Insurance Co. of Illinois, 306 Ill.App.3d 538, 544 , 239 Ill.Dec. 899 , 715 N.E.2d 653 (1999) (public policy requires that insurance contracts be construed in accord with the objectively reasonable expectations of the insured). ¶ 78 Even if the status of the reasonable expectations doctrine in Illinois is an open question, we decline to apply it here. "`The parties to an insurance contract may incorporate in it such provisions, not in violation of law, as they choose; and it is the duty of the courts to construe and enforce the contract as made. 2011Paul Insurance Co. of Illinois, 306 Ill.App.3d 538, 544 , 239 Ill.Dec. 899 , 715 N.E.2d 653 (1999) (public policy requires that insurance contracts be construed in accord with the objectively reasonable expectations of the insured). ¶ 78 Even if the status of the reasonable expectations doctrine in Illinois is an open question, we decline to apply it here. "`The parties to an insurance contract may incorporate in it such provisions, not in violation of law, as they choose; and it is the duty of the courts to construe and enforce the contract as made. | 1 | 2011–2011 |
Voorhees v. Preferred Mutual Insurance
green
1 sentence2011Under this doctrine, “if an insured’s ‘reasonable expectations’ contravene the plain meaning of a policy, even its plain meaning can be overcome.” Voorhees, 607 A.2d at 1260 (quoting Werner Industries v. First State Insurance Co., 548 A.2d 188, 191 (N.J. 1988). | 1 | 2011–2011 |
American Country Insurance Co. v. Cash
green
1 sentence1991(American Country Insurance Co. v. Cash (1988), 171 Ill. | 1 | 1991–1991 |
Insurance Co. of North America v. Adkisson
green
1 sentence1988(Insurance Co. of North America v. Adkisson (1984), 121 Ill. | 1 | 1988–1988 |
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.
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.