99 Illinois opinions name it 2 courts 1851–2026 15 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 |
|---|---|---|
Wendling v. Southern Illinois Hospital Servicesgreen2 sentences2021Accordingly, the dismissal order is an appealable order that we have jurisdiction to review. ¶3 The common fund doctrine has been described as follows: “ ‘The common fund doctrine is an exception to the general American rule that, absent a statutory provision or an agreement between the parties, each party to litigation bears its own attorney fees and may not recover those fees from an adversary. [Citation.] The doctrine provides that “ ‘ a litigant or a lawyer who recovers a common fund for the benefit of persons other than himself or his client is entitled to a reasonable attorney’s fee from 2021Accordingly, the dismissal order is an appealable order that we have jurisdiction to review. ¶3 The common fund doctrine has been described as follows: “ ‘The common fund doctrine is an exception to the general American rule that, absent a statutory provision or an agreement between the parties, each party to litigation bears its own attorney fees and may not recover those fees from an adversary. [Citation.] The doctrine provides that “ ‘ a litigant or a lawyer who recovers a common fund for the benefit of persons other than himself or his client is entitled to a reasonable attorney’s fee from | 5 | 6 |
Goldstein v. Dabs Asset Manager, Inc.green2 sentences2024Goldstein v. DABS Asset Manager, Inc., 381 Ill. 2024Goldstein v. DABS Asset Manager, Inc., 381 Ill. | 4 | 6 |
Scholtens v. Schneidergreen2 sentences2015Plaintiff contends this doctrine supports her claims, as it was only through her efforts that the City was reimbursed for the payments it made on her behalf, and the City, therefore, had an obligation under the common fund doctrine to pay for its proportionate share of the attorney fees incurred in realizing that reimbursement. ¶ 19 However, our supreme court has made it clear that the common fund doctrine is a “quasi-contractual right to payment of fees for services” that rests upon “equitable considerations of quantum meruit and the prevention of unjust enrichment.” Scholtens v. Schneider, 1 2015Plaintiff contends this doctrine supports her claims, as it was only through her efforts that the City was reimbursed for the payments it made on her behalf, and the City, therefore, had an obligation under the common fund doctrine to pay for its proportionate share of the attorney fees incurred in realizing that reimbursement. ¶ 19 However, our supreme court has made it clear that the common fund doctrine is a "quasi- contractual right to payment of fees for services" that rests upon "equitable considerations of quantum meruit and the prevention of unjust enrichment." Scholtens v. Schneider, | 4 | 4 |
Brundidge v. Glendale Federal Bank, F.S.B.green2 sentences2018Much like the mandamus action by the plaintiffs in Gassman , plaintiffs here need not pursue a private right of action under the Clerks of Courts Act in seeking the equitable relief of a declaratory judgment and return of the fees unlawfully imposed in the form of restitution. ¶ 53 Moreover, to the extent that plaintiffs argue that they are seeking attorney fees, we note that "Illinois has long adhered to the general American rule that the prevailing party in a lawsuit must bear the costs of litigation, unless a statutory provision or an agreement between the parties allows the successful liti 2018Much like the mandamus action by the plaintiffs in Gassman , plaintiffs here need not pursue a private right of action under the Clerks of Courts Act in seeking the equitable relief of a declaratory judgment and return of the fees unlawfully imposed in the form of restitution. ¶ 53 Moreover, to the extent that plaintiffs argue that they are seeking attorney fees, we note that "Illinois has long adhered to the general American rule that the prevailing party in a lawsuit must bear the costs of litigation, unless a statutory provision or an agreement between the parties allows the successful liti | 3 | 6 |
Sorenson v. Fio Ritogreen2 sentences2025However, the American rule sometimes does not apply when a plaintiff sustains “losses directly caused by the defendant’s conduct simply because those losses happen to take the form of attorneys’ fees.” Sorenson v. Fio Rito, 90 Ill. 2025However, the American rule sometimes does not apply when a plaintiff sustains “losses directly caused by the defendant’s conduct simply because those losses happen to take the form of attorneys’ fees.” Sorenson v. Fio Rito, 90 Ill. | 3 | 4 |
Toland v. Davisgreen2 sentences2001Under the common-law “American rule,” litigants are generally responsible for their own attorney fees (see, e.g., Toland v. Davis, 295 Ill. 2001Under the common-law "American rule," litigants are generally responsible for their own attorney fees (see, e.g. , Toland v. Davis , 295 Ill. | 3 | 3 |
Ritter v. Rittergreen2 sentences2025Ritter v. Ritter, 381 Ill. 549, 553 (1943). 2020Our supreme court has recognized: “[W]here the wrongful acts of a defendant involve the plaintiff in litigation with third parties or place him in such relation with others as to make it necessary to incur expense to protect his interest, the plaintiff can then recover damages against such wrongdoer, measured by the reasonable expenses of such litigation, including attorney fees.” Ritter, 381 Ill. at 554 (citing Philpot, 75 Ill. at 310-11 , McEwen, 37 Ill. at 537-38 , and Himes, 14 Ill. at 471-72 ). ¶ 85 Importantly, “[c]are must be taken to distinguish between the [‘American rule’] prohibitin | 2 | 3 |
Village of Glenview v. Zwickgreen2 sentences2019Village of Glenview v. Zwick , 356 Ill. 2019Village of Glenview v. Zwick, 356 Ill. | 2 | 3 |
Michigan Avenue National Bank v. County of Cookgreen2 sentences2020Further, we note the supreme court has held that “Illinois follows the ‘American rule,’ which prohibits prevailing parties from recovering their attorney fees from the losing party, absent express statutory or contractual provisions.” (Emphasis added.) Sandholm v. Kuecker, 2012 IL 111443, ¶ 64 , 962 N.E.2d 418 ; see also Michigan Avenue National Bank v. County of Cook, 191 Ill. 2d 493, 519 , 732 N.E.2d 528, 543 (2000) (“[T]he legislature has the inherent authority to repeal or change the common law and may do away with all or part of it.”). 2020Further, we note the supreme court has held that “Illinois follows the ‘American rule,’ which prohibits prevailing parties from recovering their attorney fees from the losing party, absent express statutory or contractual provisions.” (Emphasis added.) Sandholm v. Kuecker, 2012 IL 111443, ¶ 64 , 962 N.E.2d 418 ; see also Michigan Avenue National Bank v. County of Cook, 191 Ill. 2d 493, 519 , 732 N.E.2d 528, 543 (2000) (“[T]he legislature has the inherent authority to repeal or change the common law and may do away with all or part of it.”). | 2 | 2 |
Goodman v. Wardgreen2 sentences2012See Goodman v. Ward, 241 Ill.2d 398, 404-05 , 350 Ill.Dec. 300 , 948 N.E.2d 580 (2011). ¶ 64 Turning to the merits, Illinois follows the "American rule," which prohibits prevailing parties from recovering their attorney fees from the losing party, absent express statutory or contractual provisions. 2012See Goodman v. Ward, 241 Ill.2d 398, 404-05 , 350 Ill.Dec. 300 , 948 N.E.2d 580 (2011). ¶ 64 Turning to the merits, Illinois follows the "American rule," which prohibits prevailing parties from recovering their attorney fees from the losing party, absent express statutory or contractual provisions. | 2 | 2 |
McKenzie v. Burrisgreen2 sentences2000See, e.g. , McKenzie v. Burris , 255 Ark. 330 , 500 S.W.2d 357 (1973) (it is widely held that proceedings in suit instituted or conducted by one not entitled to practice law are a nullity, and if appropriate steps are timely taken, suit may be dismissed, a judgment may be reversed, or steps of the unauthorized practitioner disregarded); Russell v. Dopp , 36 Cal. App. 4th 765 , 42 Cal. Rptr. 2d 768 (1995) (general American rule is that unlicensed person cannot appear in court for another, and the resulting judgment is a nullity; however, client's failure to discover earlier that her attorney wa 2000See, e.g. , McKenzie v. Burris , 255 Ark. 330 , 500 S.W.2d 357 (1973) (it is widely held that proceedings in suit instituted or conducted by one not entitled to practice law are a nullity, and if appropriate steps are timely taken, suit may be dismissed, a judgment may be reversed, or steps of the unauthorized practitioner disregarded); Russell v. Dopp , 36 Cal. App. 4th 765 , 42 Cal. Rptr. 2d 768 (1995) (general American rule is that unlicensed person cannot appear in court for another, and the resulting judgment is a nullity; however, client's failure to discover earlier that her attorney wa | 2 | 2 |
Saltiel v. Olsengreen2 sentences2018Much like the mandamus action by the plaintiffs in Gassman , plaintiffs here need not pursue a private right of action under the Clerks of Courts Act in seeking the equitable relief of a declaratory judgment and return of the fees unlawfully imposed in the form of restitution. ¶ 53 Moreover, to the extent that plaintiffs argue that they are seeking attorney fees, we note that "Illinois has long adhered to the general American rule that the prevailing party in a lawsuit must bear the costs of litigation, unless a statutory provision or an agreement between the parties allows the successful liti 2018Much like the mandamus action by the plaintiffs in Gassman , plaintiffs here need not pursue a private right of action under the Clerks of Courts Act in seeking the equitable relief of a declaratory judgment and return of the fees unlawfully imposed in the form of restitution. ¶ 53 Moreover, to the extent that plaintiffs argue that they are seeking attorney fees, we note that "Illinois has long adhered to the general American rule that the prevailing party in a lawsuit must bear the costs of litigation, unless a statutory provision or an agreement between the parties allows the successful liti | 1 | 5 |
| Diamond v. General Telephone Co.green | 1 | 1 |
| National Marine, Inc. v. Illinois Environmental Protection Agencygreen | 1 | 1 |
| In Re Estate of Eliasgreen | 1 | 1 |
| Baier v. State Farm Insurance Co.green | 1 | 1 |
| City of Chicago v. Fair Employment Practices Commissiongreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Sandholm v. Kuecker
green
2 sentences2024In particular, he points out that plaintiff’s counsel billed 13.8 hours for discovery, “which amounted to [$3795] in fees taking into account Plaintiff’s stated hourly rate of $275.” Defendant contends, however, that discovery in the case “was not complicated and is not reasonably attributable to that [claimed] amount of fees.” ¶ 68 “Illinois follows the ‘American rule,’ which prohibits prevailing parties from - 22 - recovering their attorney fees from the losing party, absent express statutory or contractual provisions.” Sandholm v. Kuecker, 2012 IL 111443, ¶ 64 , 962 N.E.2d 418 . 2024In particular, he points out that plaintiff’s counsel billed 13.8 hours for discovery, “which amounted to [$3795] in fees taking into account Plaintiff’s stated hourly rate of $275.” Defendant contends, however, that discovery in the case “was not complicated and is not reasonably attributable to that [claimed] amount of fees.” ¶ 69 “Illinois follows the ‘American rule,’ which prohibits prevailing parties from recovering their attorney fees from the losing party, absent express statutory or contractual - 22 - provisions.” Sandholm v. Kuecker, 2012 IL 111443, ¶ 64 , 962 N.E.2d 418 . | 13 | 2017–2026 |
The Forest Preserve District Of Cook County v. Continental Community Bank And Trust Company
green
2 sentences2020Id. ¶ 58 Illinois has long followed the “American rule,” which provides that each party must bear its own attorney fees and costs, absent statutory authority or a contractual agreement. 2020Id. ¶ 58 Illinois has long followed the “American rule,” which provides that each party must bear its own attorney fees and costs, absent statutory authority or a contractual agreement. | 6 | 2018–2024 |
Alyeska Pipeline Service Co. v. Wilderness Society
red
2 sentences1992With respect to awards of attorney fees, the prevailing rule in the United States, often referred to as the “American rule” (Alyeska Pipeline Service Co. v. Wilderness Society (1975), 421 U.S. 240 , 44 L. 1992With respect to awards of attorney fees, the prevailing rule in the United States, often referred to as the “American rule” (Alyeska Pipeline Service Co. v. Wilderness Society (1975), 421 U.S. 240 , 44 L. | 6 | 1975–1998 |
Sandholm v. Kuecker
green
2 sentences2024In particular, he points out that plaintiff’s counsel billed 13.8 hours for discovery, “which amounted to [$3795] in fees taking into account Plaintiff’s stated hourly rate of $275.” Defendant contends, however, that discovery in the case “was not complicated and is not reasonably attributable to that [claimed] amount of fees.” ¶ 68 “Illinois follows the ‘American rule,’ which prohibits prevailing parties from - 22 - recovering their attorney fees from the losing party, absent express statutory or contractual provisions.” Sandholm v. Kuecker, 2012 IL 111443, ¶ 64 , 962 N.E.2d 418 . 2024In particular, he points out that plaintiff’s counsel billed 13.8 hours for discovery, “which amounted to [$3795] in fees taking into account Plaintiff’s stated hourly rate of $275.” Defendant contends, however, that discovery in the case “was not complicated and is not reasonably attributable to that [claimed] amount of fees.” ¶ 69 “Illinois follows the ‘American rule,’ which prohibits prevailing parties from recovering their attorney fees from the losing party, absent express statutory or contractual - 22 - provisions.” Sandholm v. Kuecker, 2012 IL 111443, ¶ 64 , 962 N.E.2d 418 . | 5 | 2017–2024 |
Oak Forest Properties, LLC v. RER Financial, Inc.
green
2 sentences2023In these circumstances, we agree with the trial court that there was no basis on which to find Landlord’s actions so outrageous that they could support an award of punitive damages. ¶ 94 We next turn to Landlord’s cross-appeal, in which it contends that the trial court erred in denying its request for attorney fees. ¶ 95 “Illinois follows the ‘American rule,’ which prohibits a prevailing party from recovering its attorney fees from the losing party absent an express statutory or contractual provision.” Oak Forest Properties, LLC v. RER Financial, Inc., 2018 IL App (1st) 161704, ¶ 12 . 2022Attorney Fees ¶ 49 “Illinois follows the ‘American rule,’ which prohibits a prevailing party from recovering its attorney fees from the losing party absent an express statutory or contractual provision.” Oak Forest Properties, LLC v. RER Financial, Inc., 2018 IL App (1st) 161704 , ¶ 12. | 4 | 2022–2025 |
People ex rel. Schad, Diamond and Shedden, P.C. v. My Pillow, Inc.
green
2 sentences2020In My Pillow, this court acknowledged that “Illinois has long followed the ‘American rule’ regarding the award of attorney fees.” My Pillow, 2018 IL 122487, ¶ 17 . 2019In My Pillow, this court acknowledged that “Illinois has long followed the ‘American rule’ regarding the award of attorney fees.” My Pillow, 2018 IL 122487, ¶ 17 . | 3 | 2019–2020 |
Willard v. Bassett
green
2 sentences2020“Under that rule, each party to litigation must normally bear its own litigation expenses, regardless of who won,” and “[p]revailing parties are prohibited from recovering their attorney fees from the losing party absent express authorization by statute or by contract between the parties.” My Pillow, 2018 IL 122487 , ¶ 17. ¶ 26 In My Pillow, we recognized that in Willard v. Bassett, 27 Ill. 37 (1861), our court expressly rejected the notion that an attorney who represents himself or herself in a legal proceeding may charge a fee for professional services in prosecuting or defending the case. 2019“Under that rule, each party to litigation must normally bear its own litigation expenses, regardless of who won,” and “[p]revailing parties are prohibited from recovering their attorney fees from the losing party absent express authorization by statute or by contract between the parties.” My Pillow, 2018 IL 122487 , ¶ 17. ¶ 26 In My Pillow, we recognized that in Willard v. Bassett, 27 Ill. 37 (1861), our court expressly rejected the notion that an attorney who represents himself or herself in a legal proceeding may charge a fee for professional services in prosecuting or defending the case. | 3 | 2019–2020 |
Hamer v. Kirk
green
2 sentences2018Much like the mandamus action by the plaintiffs in Gassman , plaintiffs here need not pursue a private right of action under the Clerks of Courts Act in seeking the equitable relief of a declaratory judgment and return of the fees unlawfully imposed in the form of restitution. ¶ 53 Moreover, to the extent that plaintiffs argue that they are seeking attorney fees, we note that "Illinois has long adhered to the general American rule that the prevailing party in a lawsuit must bear the costs of litigation, unless a statutory provision or an agreement between the parties allows the successful liti 2018Much like the mandamus action by the plaintiffs in Gassman , plaintiffs here need not pursue a private right of action under the Clerks of Courts Act in seeking the equitable relief of a declaratory judgment and return of the fees unlawfully imposed in the form of restitution. ¶ 53 Moreover, to the extent that plaintiffs argue that they are seeking attorney fees, we note that "Illinois has long adhered to the general American rule that the prevailing party in a lawsuit must bear the costs of litigation, unless a statutory provision or an agreement between the parties allows the successful liti | 3 | 1995–2018 |
Fleischmann Distilling Corp. v. Maier Brewing Co.
green
2 sentences1983While this statement correctly formulates the “American rule” (see generally Fleischmann Distilling Corp. v. Maier Brewing Co. (1967), 386 U.S. 714, 717-18 , 18 L. 1983While this statement correctly formulates the “American rule” (see generally Fleischmann Distilling Corp. v. Maier Brewing Co. (1967), 386 U.S. 714, 717-18 , 18 L. | 3 | 1980–1991 |
Gilbert v. National Cash Register Co.
green
2 sentences1933(Gilbert v. National Cash Register Co., 176 Ill. 288 ; Brundage v. Camp, 21 id. 329 .) Uniformity in the law of the several States pertaining to sales being deemed essential to the commercial welfare of the country, leaders of the American bar prepared and submitted to the legislatures of the several States a uniform sales act and a uniform conditional sales act. 1933(Gilbert v. National Cash Register Co., 176 Ill. 288 ; Brundage v. Camp, 21 id. 329 .) Uniformity in the law of the several States pertaining to sales being deemed essential to the commercial welfare of the country, leaders of the American bar prepared and submitted to the legislatures of the several States a uniform sales act and a uniform conditional sales act. | 3 | 1925–1933 |
Nalivaika v. Murphy
green
2 sentences2024Id. at 775 . ¶ 89 Plaintiff’s situation is like that of Goldstein. 2020Our supreme court has recognized: “[W]here the wrongful acts of a defendant involve the plaintiff in litigation with third parties or place him in such relation with others as to make it necessary to incur expense to protect his interest, the plaintiff can then recover damages against such wrongdoer, measured by the reasonable expenses of such litigation, including attorney fees.” Ritter, 381 Ill. at 554 (citing Philpot, 75 Ill. at 310-11 , McEwen, 37 Ill. at 537-38 , and Himes, 14 Ill. at 471-72 ). ¶ 85 Importantly, “[c]are must be taken to distinguish between the [‘American rule’] prohibitin | 2 | 2020–2024 |
City of Chicago v. Concordia Evangelical Lutheran Church
green
2 sentences2018City of Chicago v. Concordia Evangelical Lutheran Church , 2016 IL App (1st) 151864 , ¶ 85, 410 Ill.Dec. 30 , 69 N.E.3d 255 . 2018City of Chicago v. Concordia Evangelical Lutheran Church , 2016 IL App (1st) 151864 , ¶ 85, 410 Ill.Dec. 30 , 69 N.E.3d 255 . | 2 | 2018–2018 |
In re the Marriage of Pal
green
2 sentences2011In re Marriage of Pal, 397 Ill. 2011In re Marriage of Pal, 397 Ill. | 2 | 2011–2011 |
American Family Mutual Insurance v. Savickas
green
2 sentences2003Following argument on the motions, the trial court entered an order stating that, in light of the recent decision in American Family Mutual Insurance Co. v. Savickas , 193 Ill. 2d 378 (2000), it could not address the cross-motions until a duty to defend had been determined. 2003Following argument on the motions, the trial court entered an order stating that, in light of the recent decision in American Family Mutual Insurance Co. v. Savickas, 193 Ill. 2d 378 (2000), it could not address the cross-motions until a duty to defend had been determined. | 2 | 2003–2003 |
Russell v. Dopp
green
2 sentences2000See, e.g. , McKenzie v. Burris , 255 Ark. 330 , 500 S.W.2d 357 (1973) (it is widely held that proceedings in suit instituted or conducted by one not entitled to practice law are a nullity, and if appropriate steps are timely taken, suit may be dismissed, a judgment may be reversed, or steps of the unauthorized practitioner disregarded); Russell v. Dopp , 36 Cal. App. 4th 765 , 42 Cal. Rptr. 2d 768 (1995) (general American rule is that unlicensed person cannot appear in court for another, and the resulting judgment is a nullity; however, client's failure to discover earlier that her attorney wa 2000See, e.g. , McKenzie v. Burris , 255 Ark. 330 , 500 S.W.2d 357 (1973) (it is widely held that proceedings in suit instituted or conducted by one not entitled to practice law are a nullity, and if appropriate steps are timely taken, suit may be dismissed, a judgment may be reversed, or steps of the unauthorized practitioner disregarded); Russell v. Dopp , 36 Cal. App. 4th 765 , 42 Cal. Rptr. 2d 768 (1995) (general American rule is that unlicensed person cannot appear in court for another, and the resulting judgment is a nullity; however, client's failure to discover earlier that her attorney wa | 2 | 2000–2000 |
Turkey Point Property Owners' Ass'n v. Anderson
green
2 sentences2000See, e.g. , McKenzie v. Burris , 255 Ark. 330 , 500 S.W.2d 357 (1973) (it is widely held that proceedings in suit instituted or conducted by one not entitled to practice law are a nullity, and if appropriate steps are timely taken, suit may be dismissed, a judgment may be reversed, or steps of the unauthorized practitioner disregarded); Russell v. Dopp , 36 Cal. App. 4th 765 , 42 Cal. Rptr. 2d 768 (1995) (general American rule is that unlicensed person cannot appear in court for another, and the resulting judgment is a nullity; however, client's failure to discover earlier that her attorney wa 2000See, e.g., McKenzie v. Burris, 255 Ark. 330 , 500 S.W.2d 357 (1973) (it is widely held that proceedings in suit instituted or conducted by one not entitled to practice law are a nullity, and if appropriate steps are timely taken, suit may be dismissed, a judgment may be reversed, or steps of the unauthorized practitioner disregarded); Russell v. Dopp, 36 Cal. App. 4th 765 , 42 Cal. Rptr. 2d 768 (1995) (general American rule is that unlicensed person cannot appear in court for another, and the resulting judgment is a nullity; however, client’s failure to discover earlier that her attorney was u | 2 | 2000–2000 |
Niklaus v. Abel Construction Company
green
2 sentences2000App. 710 , 666 A.2d 904 (1995) (nonlawyer's filing of petition and representation of association at trial rendered petition as well as trial proceedings a nullity; judgment vacated); Gonsior v. Alternative Staffing, Inc. , 390 N.W.2d 801 (Minn. App. 1986) (under general nullity rule, appeal by one not licensed to represent another would be dismissed where client consciously chose to be represented by nonattorney; under the facts, rule would be applied in future); Niklaus v. Abel Construction Co. , 164 Neb. 842 , 83 N.W.2d 904 (1957) (action was brought on behalf of municipality by disbarred la 2000App. 710 , 666 A.2d 904 (1995) (nonlawyer's filing of petition and representation of association at trial rendered petition as well as trial proceedings a nullity; judgment vacated); Gonsior v. Alternative Staffing, Inc. , 390 N.W.2d 801 (Minn. App. 1986) (under general nullity rule, appeal by one not licensed to represent another would be dismissed where client consciously chose to be represented by nonattorney; under the facts, rule would be applied in future); Niklaus v. Abel Construction Co. , 164 Neb. 842 , 83 N.W.2d 904 (1957) (action was brought on behalf of municipality by disbarred la | 2 | 2000–2000 |
Alliance Group, Inc. v. Rosenfield
green
2 sentences2000App. 710 , 666 A.2d 904 (1995) (nonlawyer's filing of petition and representation of association at trial rendered petition as well as trial proceedings a nullity; judgment vacated); Gonsior v. Alternative Staffing, Inc. , 390 N.W.2d 801 (Minn. App. 1986) (under general nullity rule, appeal by one not licensed to represent another would be dismissed where client consciously chose to be represented by nonattorney; under the facts, rule would be applied in future); Niklaus v. Abel Construction Co. , 164 Neb. 842 , 83 N.W.2d 904 (1957) (action was brought on behalf of municipality by disbarred la 2000App. 710 , 666 A.2d 904 (1995) (nonlawyer's filing of petition and representation of association at trial rendered petition as well as trial proceedings a nullity; judgment vacated); Gonsior v. Alternative Staffing, Inc. , 390 N.W.2d 801 (Minn. App. 1986) (under general nullity rule, appeal by one not licensed to represent another would be dismissed where client consciously chose to be represented by nonattorney; under the facts, rule would be applied in future); Niklaus v. Abel Construction Co. , 164 Neb. 842 , 83 N.W.2d 904 (1957) (action was brought on behalf of municipality by disbarred la | 2 | 2000–2000 |
| House of Vision, Inc. v. Hiyane green | 2 | 1985–1993 |
| State Farm Fire & Casualty Co. v. Miller Electric Co. green | 2 | 1993–1993 |
| American Aviation Supply v. Illinois Department of Revenue neutral | 1 | 2024–2024 |
| Garlick v. Bloomingdale Township green | 1 | 2022–2022 |
| Stefanski v. The City of Chicago green | 1 | 2021–2021 |
| In re Estate of Martin green | 1 | 2020–2020 |
| Himies v. Keighblingher green | 1 | 2020–2020 |
| McEwen v. Kerfoot green | 1 | 2020–2020 |
| Philpot v. Taylor green | 1 | 2020–2020 |
| Young v. Alden Gardens of Waterford, LLC green | 1 | 2020–2020 |
| Peleton, Inc. v. McGivern's, Inc. green | 1 | 2018–2018 |
| Ferguson v. Patton green | 1 | 2017–2017 |
| Duignan v. Lincoln Towers Ins. Agency green | 1 | 2008–2008 |
| Gonsior v. Alternative Staffing, Inc. green | 1 | 2000–2000 |
| Cummings v. Beaton & Associates, Inc. green | 1 | 1996–1996 |
| Chambers v. Nasco, Inc. green | 1 | 1996–1996 |
| Lord v. Hubert green | 1 | 1994–1994 |
| Wolens v. American Airlines neutral | 1 | 1993–1993 |
| Baksinski v. Northwestern University green | 1 | 1993–1993 |
| Wolens v. American Airlines, Inc. green | 1 | 1993–1993 |
| cluster 496741 green | 1 | 1992–1992 |
| Harvey v. Carponelli green | 1 | 1991–1991 |
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.