rationale supporting rule (Illinois) · Go Syfert
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rationale supporting rule in Illinois

17 Illinois opinions name it 2 courts 1968–2023 2 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 (6)

CaseFollowedCited
Beetle v. Wal-Mart Associates, Inc.green
illappct · 2001 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023“The rationale supporting this rule is that the nature and circumstances surrounding the traumatic event are such that the injured party is thereby put on notice that actionable conduct might be involved.” Golla, 167 Ill. 2d at 363 . ¶ 47 “A traumatic injury is one in which the damage is caused by external violence or in which the injury is immediate and caused by an external force.” Beetle v. Wal-Mart Associates, Inc., 326 Ill.

11
Castello v. Kalisgreen
illappct · 2004 · cited in 1 Illinois opinions naming this issue, 2022–2022
1 sentence

2022“The rationale supporting this rule is that the nature and circumstances surrounding the traumatic event are such that the injured party is thereby put on notice that actionable conduct might be involved.” Golla, 167 Ill. 2d at 363 . ¶ 21 Further, and most notably here, knowledge that an injury has been wrongfully caused “does not mean knowledge of a specific defendant’s negligent conduct or knowledge of the existence of a cause of action.” (Emphasis and internal quotation marks omitted.) Castello v. Kalis, 352 Ill.

11
In the Matter of the Estate of Johnny VAJGRT, Deceased, Bill Ernst, Inc., Intervenor-Appellantgreen
iowa · 2011 · cited in 1 Illinois opinions naming this issue, 2014–2014
2 sentences

2014See Vajgrt, 801 N.W.2d at 577 n.6; see also Munson v. Raudonis, 387 A.2d 1174, 1177 (N.H. 1978) (holding that, although New Hampshire law does not allow for punitive damages, compensatory damages survive the death of the tortfeasor and “compensatory damages awarded may reflect the aggravating circumstances” when wanton, malicious, or oppressive conduct is involved (internal quotation marks omitted)). ¶ 89 Justice Hecht, dissenting in Vajgrt, believed that the rationale supporting the rule against punishing the wrongdoer’s heirs for his or her malicious conduct was gravely flawed.

2014Vajgrt, 801 N.W.2d at 578 (Hecht, J., dissenting).

11
Munson v. Raudonisgreen
nh · 1978 · cited in 1 Illinois opinions naming this issue, 2014–2014
1 sentence

2014See Vajgrt, 801 N.W.2d at 577 n.6; see also Munson v. Raudonis, 387 A.2d 1174, 1177 (N.H. 1978) (holding that, although New Hampshire law does not allow for punitive damages, compensatory damages survive the death of the tortfeasor and “compensatory damages awarded may reflect the aggravating circumstances” when wanton, malicious, or oppressive conduct is involved (internal quotation marks omitted)). ¶ 89 Justice Hecht, dissenting in Vajgrt, believed that the rationale supporting the rule against punishing the wrongdoer’s heirs for his or her malicious conduct was gravely flawed.

11
Miller v. Sutliffgreen
ill · 1909 · cited in 1 Illinois opinions naming this issue, 2012–2012
2 sentences

2012A mere breach of a contract does not amount to a fraud, and neither a -9- knowledge of inability to perform, nor an intention not to do so, would make the transaction fraudulent.” Miller v. Sutliff, 241 Ill. 521, 526-27 , 89 N.E. 651, 652 (1909). ¶ 33 This promissory fraud doctrine is limited, however, by the rule that even such fraud is actionable if it was part of a scheme or artifice to defraud.

2012A mere breach of a contract does not amount to a fraud, and neither a -9- knowledge of inability to perform, nor an intention not to do so, would make the transaction fraudulent.” Miller v. Sutliff, 241 Ill. 521, 526-27 , 89 N.E. 651, 652 (1909). ¶ 33 This promissory fraud doctrine is limited, however, by the rule that even such fraud is actionable if it was part of a scheme or artifice to defraud.

11
The People v. Trefonasgreen
ill · 1956 · cited in 1 Illinois opinions naming this issue, 1968–1968
1 sentence

1968See People v. Trefonas, 9 Ill2d 92, 136 NE2d 817 (1956), for the rationale supporting this rule.

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 (9)

CaseCitedYears
Golla v. General Motors Corp. green
ill · 1995
2 sentences

2023“The rationale supporting this rule is that the nature and circumstances surrounding the traumatic event are such that the injured party is thereby put on notice that actionable conduct might be involved.” Golla, 167 Ill. 2d at 363 . ¶ 47 “A traumatic injury is one in which the damage is caused by external violence or in which the injury is immediate and caused by an external force.” Beetle v. Wal-Mart Associates, Inc., 326 Ill.

2022“The rationale supporting this rule is that the nature and circumstances surrounding the traumatic event are such that the injured party is thereby put on notice that actionable conduct might be involved.” Golla, 167 Ill. 2d at 363 . ¶ 21 Further, and most notably here, knowledge that an injury has been wrongfully caused “does not mean knowledge of a specific defendant’s negligent conduct or knowledge of the existence of a cause of action.” (Emphasis and internal quotation marks omitted.) Castello v. Kalis, 352 Ill.

71996–2023
In re Marriage of Olsen green
illappct · 1992
1 sentence

1996Olsen, 229 Ill.

11996–1996
Kirk v. Michael Reese Hospital & Medical Center green
ill · 1987
2 sentences

1994(Kirk, 117 Ill. 2d at 519 , 513 N.E.2d at 393 .) The rationale supporting the doctrine is that the physician functions as the learned intermediary between the manufacturer and the patient and decides which drug to prescribe and which warnings should be conveyed to the patient.

1994(Kirk, 117 Ill. 2d at 519 , 513 N.E.2d at 393 .) The rationale supporting the doctrine is that the physician functions as the learned intermediary between the manufacturer and the patient and decides which drug to prescribe and which warnings should be conveyed to the patient.

11994–1994
Nix v. Williams green
scotus · 1984
2 sentences

1991(Nix, 467 U.S. 431 , 81 L.

1991(Nix, 467 U.S. 431 , 81 L.

11991–1991
People v. Hicks green
ill · 1989
1 sentence

1989The majority decides that by initiating conversation with the police officer about the Fayette Service Co-op burglary, defendant completely waived his previously invoked right to counsel, including his right to have counsel present during police interrogation pertaining to crimes unrelated to the Fayette Service Co-op burglary. ( 132 Ill.2d at 495 .) The majority concludes: "Logic would suggest that if the virtue of a bright line rule — the ease of application — supports cutting off all interrogation when an accused requests counsel, then the virtue of a bright line rule would permit interroga

11989–1989
Harry v. Harry neutral
illappct · 1976
1 sentence

1981App. 3d 776, 778 , 349 N.E.2d 69 , appeal denied (1976), 64 Ill. 2d 596 .) The rationale supporting such a rule (i.e., adequate notice of claim cures error in form) does not apply with equal force to the present situation.

11981–1981
People v. Wright green
illappct · 1965
1 sentence

1976“Since it is the failure to deny that is significant; an equivocal or evasive response may similarly be used against him.” (McCormick, Evidence §270, at 651-53 (2d ed. 1972).) The problem of the evasive answer (as opposed to silence) is considered in 3 Warton’s Criminal Evidence §701, at 505 (13th ed. 1973): “An evasive or unresponsive reply to an incriminating or accusatory statement is tantamount to silence, in which case the statement and the reply are admissible as an admission of the statement’s truth.” The case of People v. Wright, 65 Ill.

11976–1976
People v. Leggett green
illappct · 1971
2 sentences

1972People v. Leggett, 2 Ill.App.3d 962 , 275 N.E.2d 651 , and People v. Short, 4 Ill.App.3d 849 , 281 N.E.2d 785 , are based on the premise that reversing the conviction for the lesser offense growing out of the same conduct is a complimentary application of the main rule even though the issue has not been specifically discussed in Supreme Court decisions.

1972People v. Leggett, 2 Ill.App.3d 962 , 275 N.E.2d 651 , and People v. Short, 4 Ill.App.3d 849 , 281 N.E.2d 785 , are based on the premise that reversing the conviction for the lesser offense growing out of the same conduct is a complimentary application of the main rule even though the issue has not been specifically discussed in Supreme Court decisions.

11972–1972
People v. Short green
illappct · 1972
2 sentences

1972People v. Leggett, 2 Ill.App.3d 962 , 275 N.E.2d 651 , and People v. Short, 4 Ill.App.3d 849 , 281 N.E.2d 785 , are based on the premise that reversing the conviction for the lesser offense growing out of the same conduct is a complimentary application of the main rule even though the issue has not been specifically discussed in Supreme Court decisions.

1972People v. Leggett, 2 Ill.App.3d 962 , 275 N.E.2d 651 , and People v. Short, 4 Ill.App.3d 849 , 281 N.E.2d 785 , are based on the premise that reversing the conviction for the lesser offense growing out of the same conduct is a complimentary application of the main rule even though the issue has not been specifically discussed in Supreme Court decisions.

11972–1972

Statutes the citing opinions construe

IL § 735 ILCS 5/2-619 (4) IL § 735 ILCS 5/13-202 (3) IL § 735 ILCS 5/2-615 (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 17 (1968–2023) CA 13 (1962–2016) TX 8 (1985–2021) MI 7 (1990–2017) NC 4 (1976–2018) TN 4 (2018–2025) IN 4 (1981–1999) WA 4 (1997–2000) VA 3 (1990–2025) ND 3 (1981–2009) NY 3 (1991–2021) IA 3 (1995–2010) NJ 2 (2000–2007) SC 2 (2021–2021) MD 2 (1990–2016) PA 2 (1946–1991) OH 2 (2005–2007) CO 2 (1982–2014) LA 2 (1989–1997) KY 2 (1985–2018)

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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