enforceable claim (Illinois) · Go Syfert
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enforceable claim in Illinois

14 Illinois opinions name it 2 courts 1936–2025 1 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 (4)

CaseFollowedCited
Golla v. General Motors Corp.green
ill · 1995 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011See Golla v. General Motors Corp., 167 Ill. 2d 353, 364 , 657 N.E.2d 894, 900 (1995) (“the limitations period commences when the plaintiff is injured, rather than when the plaintiff realizes the consequences of the injury or the full extent of her injuries”); Black’s Law Dictionary 21 (7th ed. 1999) (defining “accrue” as “[t]o come into existence as an enforceable claim or right”).

2011See Golla v. General Motors Corp., 167 Ill. 2d 353, 364 , 657 N.E.2d 894, 900 (1995) (“the limitations period commences when the plaintiff is injured, rather than when the plaintiff realizes the consequences of the injury or the full extent of her injuries”); Black’s Law Dictionary 21 (7th ed. 1999) (defining “accrue” as “[t]o come into existence as an enforceable claim or right”).

22
Kraftco Corp. v. Koblusgreen
illappct · 1971 · cited in 3 Illinois opinions naming this issue, 1988–2025
2 sentences

2025App. 3d 680, 688 (1991); see Kraftco Corp. v. Kolbus, 1 Ill.

1991(Kraftco Corp., 1 Ill.

13
Penzell v. Taylorgreen
illappct · 1991 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025In fact, some - 14 - Illinois courts have found that “the phrase ‘best efforts’ is too indefinite and uncertain to be an enforceable standard.” Penzell v. Taylor, 219 Ill.

11
Wells v. State Farm Fire & Casualty Insurance Co.green
illappct · 2021 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025In other cases, Illinois courts have held that the “phrase ‘best efforts’ was the equivalent of ‘reasonable efforts.’ ” Wells, 2021 IL App (5th) 190460, ¶ 35 (collecting cases).

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 (7)

CaseCitedYears
In Re Marriage of Centioli green
illappct · 2002
2 sentences

2016App. 3d 959, 964 (1980)). ¶ 45 To find an extant property interest in 1992 and 1993, petitioner argues that his cause of action “consists of the operative facts on which a right to sue is based, even if that lawsuit does not ‘accrue’ until all the legal predicates establishing an enforceable claim or right are present.” Defining a “cause of action” in this way—the presence of the operative facts of a lawsuit even though the lawsuit has not accrued—petitioner argues his cause of action, in other words the property at issue, existed in 1992 and 1993. 2 Petitioner argues respondent’s reliance on

2016App. 3d 959, 964 (1980)). ¶ 45 To find an extant property interest in 1992 and 1993, petitioner argues that his cause of action “consists of the operative facts on which a right to sue is based, even if that lawsuit does not ‘accrue’ until all the legal predicates establishing an enforceable claim or right are present.” Defining a “cause of action” in this way—the presence of the operative facts of a lawsuit even though the lawsuit has not accrued—petitioner argues his cause of action, in other words the property at issue, existed in 1992 and 1993. 2 Petitioner argues respondent’s reliance on

32016–2016
Reider v. Arthur Andersen, LLP green
connsuperct · 2001
2 sentences

2011“Because the [Insurance] Commissioner had the right and duty to take [the company] over and manage its affairs on behalf of the public if its insolvency was threatened, the company itself ha[d] an enforceable claim against any person or entity who unlawfully contributed materially to its insolvency by violating a legal duty to advise it, either directly or through the Commissioner, as to its true financial status.” Reider, 784 A.2d at 475 . ¶ 38 Applying the holding and reasoning in Reider to the facts before it, the McRaith court reversed the trial court and held that the guilty knowledge and

2009“Because the [Insurance] commissioner had the right and duty to take it over and manage [the principal’s] affairs on behalf of the public if its insolvency was threatened, the company itself had an enforceable claim against any person or entity who unlawfully contributed materially to its insolvency by violating a legal duty to advise it, either directly or through the commissioner, as to true financial status.” Reider, 47 Conn. Supp. at 219 , 784 A.2d at 475 .

22009–2011
McRaith v. BDO Seidman, LLP green
illappct · 2009
1 sentence

2011McRaith, 391 Ill.

12011–2011
Brucker v. Mercola green
ill · 2007
2 sentences

2007Analyzing the term "accrued" for the purposes of sections 13-212(b) and (c), the majority finds that it means that facts exist that authorize the bringing of a cause of action or that the claim has come into being as an enforceable claim or right. 227 Ill.2d at 544 , 319 Ill.Dec. at 561-62 , 886 N.E.2d at 324-25 .

2007Analyzing the term "accrued" for the purposes of sections 13-212(b) and (c), the majority finds that it means that facts exist that authorize the bringing of a cause of action or that the claim has come into being as an enforceable claim or right. 227 Ill.2d at 544 , 319 Ill.Dec. at 561-62 , 886 N.E.2d at 324-25 .

12007–2007
In re Parentage of M.M.W. green
illappct · 1998
1 sentence

2002M.M.W., 296 Ill.

12002–2002
Byalos v. Matheson neutral
illappct · 1926
1 sentence

1942Byalos v. Matheson, 243 Ill.

11942–1942
Moorehead's Estate green
pa · 1927
2 sentences

1936The leading case holding that such a trust fund may be reached for the support of a wife or child is that of Moorehead’s Estate, 289 Pa. 542 , 137 Atl. 802 .

1936The leading case holding that such a trust fund may be reached for the support of a wife or child is that of Moorehead’s Estate, 289 Pa. 542 , 137 Atl. 802 .

11936–1936

Statutes the citing opinions construe

IL § 225 ILCS 450/0.01 (3) IL § 745 ILCS 10/8-101 (3) IL § 750 ILCS 5/503 (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

MS 86 (1935–2024) CA 32 (1913–2026) GA 27 (1965–2024) AL 23 (1909–2014) TX 19 (1926–2019) NC 18 (1946–2024) NY 15 (1932–2011) IL 14 (1936–2025) FL 14 (1954–2024) WI 14 (1954–2009) NJ 10 (1986–2024) MA 10 (1980–2023) KS 8 (1960–2021) PA 8 (1943–2023) IA 7 (1904–2025) HI 7 (2002–2025) CT 7 (1977–2019) CO 6 (1902–2021) LA 6 (1957–2005) NM 5 (1999–2019) DE 5 (1940–2021) MO 5 (1913–1999) MI 5 (1992–2018) ND 4 (1988–2012) MN 4 (1995–2014) UT 4 (1954–2019) IN 4 (1917–2012) OH 4 (2010–2024) WA 3 (1902–1982) SD 3 (1943–2022) VT 3 (2003–2016) VA 3 (2004–2017) NE 2 (1938–2017) NH 2 (1988–1995)

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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