publication requirement (Illinois) · Go Syfert
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publication requirement in Illinois

14 Illinois opinions name it 2 courts 1978–2025 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.

Followed or applied (6)

CaseFollowedCited
Popko v. Continental Casualty Co.green
illappct · 2005 · cited in 2 Illinois opinions naming this issue, 2020–2021
2 sentences

2021Popko v. Continental Casualty Co., 355 Ill.

2020Popko v. Continental Casualty Co., 355 Ill.

22
Lewis v. Equitable Life Assurance Society of the United Statesgreen
minn · 1986 · cited in 2 Illinois opinions naming this issue, 2007–2007
2 sentences

2007Thus, these courts have held that, “in an action for defamation, the publication requirement may be satisfied where the plaintiff was compelled to publish a defamatory statement to a third person if it was foreseeable to the defendant that the plaintiff would be so compelled.” Lewis, 389 N.W.2d at 888 ; see also McKinney, 110 Cal. App. 3d at 797-98 , 168 Cal. Rptr. at 94 ; Churchey, 759 P.2d at 1345 .

2007Thus, these courts have held that, "in an action for defamation, the publication requirement may be satisfied where the plaintiff was compelled to publish a defamatory statement to a third person if it was foreseeable to the defendant that the plaintiff would be so compelled." Lewis, 389 N.W.2d at 888 ; see also McKinney, 110 Cal.App.3d at 797-98 , 168 Cal.Rptr. at 94 ; Churchey, 759 P.2d at 1345 .

22
McKinney v. County of Santa Claragreen
calctapp · 1980 · cited in 2 Illinois opinions naming this issue, 2007–2007
2 sentences

2007Thus, these courts have held that, "in an action for defamation, the publication requirement may be satisfied where the plaintiff was compelled to publish a defamatory statement to a third person if it was foreseeable to the defendant that the plaintiff would be so compelled." Lewis, 389 N.W.2d at 888 ; see also McKinney, 110 Cal.App.3d at 797-98 , 168 Cal.Rptr. at 94 ; Churchey, 759 P.2d at 1345 .

2007Thus, these courts have held that, "in an action for defamation, the publication requirement may be satisfied where the plaintiff was compelled to publish a defamatory statement to a third person if it was foreseeable to the defendant that the plaintiff would be so compelled." Lewis, 389 N.W.2d at 888 ; see also McKinney, 110 Cal.App.3d at 797-98 , 168 Cal.Rptr. at 94 ; Churchey, 759 P.2d at 1345 .

22
Blair v. Nevada Landing Partnership, RBG, LPgreen
illappct · 2006 · cited in 1 Illinois opinions naming this issue, 2025–2025
2 sentences

2025Blair v. Nevada Landing Partnership, RBG, LP, 369 Ill.

2025Id. at 325 . ¶ 41 The Samlers assert that if, as Rosenbaum contends, the Wiczer letter effectively reproduces the Goldberg letter, then under the single publication rule, both letters are time-barred. ¶ 42 Rosenbaum argues his claims are not time-barred under the continuing tort doctrine.

11
Shively v. Bozanichgreen
cal · 2003 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021App. 3d at 326 (finding that the photo was “delivered to a mass sector of the public”); see, e.g., Shively, 80 P.3d at 689 (holding that the single publication rule applied to book that had been “generally distributed to the public”); Long v. Walt Disney Co., 10 Cal. Rptr. 3d 836, 842 (Ct. App. 2004) (explaining that, “like a publication in a nationally distributed book, newspaper, or magazine, the broadcasts on national television over a period of many months meant that plaintiffs had access to them, if only as members of the general public”); see also Long, 10 - 13 - Cal. Rptr. 3d at 841 (“T

11
Long v. Walt Disney Co.green
calctapp · 2004 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021App. 3d at 326 (finding that the photo was “delivered to a mass sector of the public”); see, e.g., Shively, 80 P.3d at 689 (holding that the single publication rule applied to book that had been “generally distributed to the public”); Long v. Walt Disney Co., 10 Cal. Rptr. 3d 836, 842 (Ct. App. 2004) (explaining that, “like a publication in a nationally distributed book, newspaper, or magazine, the broadcasts on national television over a period of many months meant that plaintiffs had access to them, if only as members of the general public”); see also Long, 10 - 13 - Cal. Rptr. 3d at 841 (“T

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
Andrews v. Foxworthy green
ill · 1978
2 sentences

1994In Andrews, a group of taxpayers filed a petition for a refund of part of their 1972 real estate taxes, alleging that part of the tax was invalid because the county had failed to publish increases by July 10, 1972, the date upon which the statute stated the publication "shall be made.” (Andrews, 71 Ill. 2d at 16-17 .) Our supreme court, citing People v. Jennings (1954), 3 Ill. 2d 125, 128 , held that the purpose of the publication requirement was not merely for the guidance of public officers, nor was it solely for the provision of notice of the assessment to taxpayers.

1981And, in a case which involved another section of the Revenue Act, the supreme court held that a publication requirement designed for the benefit and protection of citizens was a mandatory provision. ( Andrews v. Foxworthy (1978), 71 Ill.2d 13 , 373 N.E.2d 1332 .) As a mandatory statute, strict compliance was required.

51981–2003
Churchey v. Adolph Coors Co. green
colo · 1988
2 sentences

2007Thus, these courts have held that, “in an action for defamation, the publication requirement may be satisfied where the plaintiff was compelled to publish a defamatory statement to a third person if it was foreseeable to the defendant that the plaintiff would be so compelled.” Lewis, 389 N.W.2d at 888 ; see also McKinney, 110 Cal. App. 3d at 797-98 , 168 Cal. Rptr. at 94 ; Churchey, 759 P.2d at 1345 .

2007Thus, these courts have held that, "in an action for defamation, the publication requirement may be satisfied where the plaintiff was compelled to publish a defamatory statement to a third person if it was foreseeable to the defendant that the plaintiff would be so compelled." Lewis, 389 N.W.2d at 888 ; see also McKinney, 110 Cal.App.3d at 797-98 , 168 Cal.Rptr. at 94 ; Churchey, 759 P.2d at 1345 .

22007–2007
Taylor v. The Board of Education of the City of Chicago green
illappct · 2014
1 sentence

2025Under that doctrine, when a tort “involves continuous or repeated injurious behavior, *** the limitations period is held in abeyance and the plaintiff’s cause of action does not accrue until the date the final injury occurs or the tortuous acts cease.” Taylor v. Board of Education of Chicago, 2014 IL App (1st) 123744, ¶ 46 .

12025–2025
Ciolino v. Simon green
ill · 2021
2 sentences

2024“The single-publication rule *** applies where defamatory material is mass-published to the public in a medium where the delayed receipt of the defamatory material is incidental to the medium’s mode of distribution.” Ciolino v. Simon, 2021 IL 126024, ¶ 38 , 192 N.E.3d 579, 587 . ¶ 67 On appeal, Süd initially contends the trial court erred because the single publication rule “has no bearing” on its slander of title claims.

2024“The single-publication rule *** applies where defamatory material is mass-published to the public in a medium where the delayed receipt of the defamatory material is incidental to the medium’s mode of distribution.” Ciolino v. Simon, 2021 IL 126024, ¶ 38 , 192 N.E.3d 579, 587 . ¶ 67 On appeal, Süd initially contends the trial court erred because the single publication rule “has no bearing” on its slander of title claims.

12024–2024
People v. Jennings green
ill · 1954
1 sentence

1994In Andrews, a group of taxpayers filed a petition for a refund of part of their 1972 real estate taxes, alleging that part of the tax was invalid because the county had failed to publish increases by July 10, 1972, the date upon which the statute stated the publication "shall be made.” (Andrews, 71 Ill. 2d at 16-17 .) Our supreme court, citing People v. Jennings (1954), 3 Ill. 2d 125, 128 , held that the purpose of the publication requirement was not merely for the guidance of public officers, nor was it solely for the provision of notice of the assessment to taxpayers.

11994–1994
PEOPLE EX REL. CHICAGO HEIGHTS v. Richton green
ill · 1969
1 sentence

1979City of Chicago Heights v. Richton (1969), 43 Ill. 2d 267 , and Perkins v. Board of County Commissioners (1916), 271 Ill. 449 .) In Garcia, we considered the publication requirement of section 104 of the Revenue Act of 1939 (Ill.

11979–1979
Perkins v. Board of County Commissioners green
ill · 1916
1 sentence

1979City of Chicago Heights v. Richton (1969), 43 Ill. 2d 267 , and Perkins v. Board of County Commissioners (1916), 271 Ill. 449 .) In Garcia, we considered the publication requirement of section 104 of the Revenue Act of 1939 (Ill.

11979–1979
People Ex Rel. Republican-Reporter Corp. v. Holmes green
illappct · 1968
2 sentences

1978In People v. Holmes (1968), 98 Ill.

1978In People v. Holmes (1968), 98 Ill.

11978–1978

Statutes the citing opinions construe

IL § 735 ILCS 5/2-619 (5) IL § 740 ILCS 165/1 (4) IL § 735 ILCS 5/13-201 (3) IL § 735 ILCS 5/13-217 (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

NY 44 (1912–2025) CA 24 (1943–2026) TX 18 (1937–2024) IL 14 (1978–2025) AR 12 (1903–2016) NJ 11 (1974–2018) IN 11 (1977–2013) PA 11 (1970–2023) CT 10 (1996–2024) FL 9 (1993–2025) GA 8 (1978–2022) MI 7 (1977–2018) LA 6 (1957–2026) OH 5 (2003–2024) CO 5 (1901–2021) ID 5 (2007–2019) MA 5 (2003–2024) KY 5 (1918–2013) VA 5 (1996–2003) MS 5 (1965–2008) AL 4 (1986–2025) DE 4 (2000–2020) TN 4 (1997–1999) WI 4 (1940–2019) WA 4 (2008–2018) HI 4 (1931–2004) MO 4 (1899–2000) IA 3 (1953–2020) NM 3 (2003–2019) MD 3 (1972–2020) NE 3 (2004–2024) OK 2 (2011–2014) MT 2 (1973–2025) MN 2 (1986–1994) OR 2 (1996–2003) AZ 2 (2001–2014) RI 2 (1973–1997)

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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