pari materia doctrine (Illinois) · Go Syfert
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pari materia doctrine in Illinois

98 Illinois opinions name it 2 courts 1979–2026 12 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 (22)

CaseFollowedCited
Land v. Board of Educ. of City of Chicagogreen
ill · 2002 · cited in 24 Illinois opinions naming this issue, 2005–2020
2 sentences

2018Under the doctrine of in pari materia, two sections of the same statute “will be considered with reference to each other, ‘so that they may be given harmonious effect.’ ” Collinsville Community Unit School District No. 10 v. Regional Board of School Trustees, 218 Ill. 2d 175, 185 (2006) (quoting Land v. Board of Education of the City of Chicago, 202 Ill. 2d 414, 422 (2002)).

2017Under the doctrine of in pari materia , two sections of the same statute "will be considered with reference to each other, 'so that they may be given harmonious effect.' " Collinsville Community Unit School District No. 10 v. Regional Board of School Trustees , 218 Ill. 2d 175 , 185, 300 Ill.Dec. 15 , 843 N.E.2d 273 (2006) (quoting Land v. Board of Education of the City of Chicago , 202 Ill. 2d 414 , 422, 269 Ill.Dec. 452 , 781 N.E.2d 249 (2002) ).

1724
People v. McCartygreen
ill · 2006 · cited in 19 Illinois opinions naming this issue, 2007–2025
2 sentences

2021We disagree. ¶ 27 The doctrine of in pari materia allows “two statutes dealing with the same subject [to] be considered with reference to one another to give them harmonious effect.” People v. McCarty, 223 Ill. 2d 109, 133 (2006).

2020“Under the doctrine of in pari materia, two statutes dealing with the same subject will be considered with reference to one another to give them harmonious effect.” People v. McCarty, 223 Ill. 2d 109, 133 (2006).

1619
Collinsville Community Unit School District No. 10 v. Regional Board of School Trusteesgreen
ill · 2006 · cited in 13 Illinois opinions naming this issue, 2006–2020
2 sentences

2018Under the doctrine of in pari materia, two sections of the same statute “will be considered with reference to each other, ‘so that they may be given harmonious effect.’ ” Collinsville Community Unit School District No. 10 v. Regional Board of School Trustees, 218 Ill. 2d 175, 185 (2006) (quoting Land v. Board of Education of the City of Chicago, 202 Ill. 2d 414, 422 (2002)).

2017One such aid is the doctrine of in pari materia, pursuant to which we construe two statutes dealing with the same subject “so that they may be given harmonious effect.” (Internal quotation marks omitted.) Collinsville Community Unit School District No. 10 v. Regional Board of School Trustees, 218 Ill. 2d 175, 185 (2006).

1213
People v. Taylorgreen
ill · 2006 · cited in 9 Illinois opinions naming this issue, 2006–2026
2 sentences

2010See Taylor, 221 Ill. 2d at 163 (“if the language of a statute is ambiguous, we may look to tools of interpretation — such as the doctrine of in pari materia — to ascertain the meaning of a provision”).

2006Furthermore, criminal or penal statutes are to ‘be strictly construed in favor of the accused, and nothing should be taken by intendment or implication beyond the obvious or literal meaning of the statute.’ People v. Laubscher, 183 Ill. 2d 330, 337 (1998). *** However, if the language of a statute is ambiguous, we may look to tools of interpretation — such as the doctrine of in pari materia — to ascertain the meaning of a provision.” Taylor, 221 Ill. 2d at 162-63 .

49
People v. 1946 Buick, Vin 34423520green
ill · 1989 · cited in 5 Illinois opinions naming this issue, 1996–2022
2 sentences

2022See 1946 Buick, 127 Ill. 2d at 377 ; Wal-Mart, 324 Ill.

1996The doctrine of in pari materia applies only if the statutory section is ambiguous. 1946 Buick, 127 Ill. 2d at 377 .

45
Brown v. Cook County Forest Preservegreen
illappct · 1996 · cited in 3 Illinois opinions naming this issue, 2016–2017
2 sentences

2017See Brown, 284 Ill.

2016See Brown, 284 Ill.

33
People v. Rowellgreen
illappct · 2021 · cited in 2 Illinois opinions naming this issue, 2026–2026
2 sentences

2026See People v. Rowell, 2020 IL App (4th) 190231, ¶ 17 .

2026See People v. Rowell, 2020 IL App (4th) 190231, ¶ 17 .

22
Blum v. Kostergreen
ill · 2009 · cited in 2 Illinois opinions naming this issue, 2016–2017
2 sentences

2017Blum v. Koster, 235 Ill. 2d 21, 29 (2009).

2016Blum v. Koster, 235 Ill. 2d 21, 29 (2009).

22
Holly v. Montesgreen
ill · 2008 · cited in 2 Illinois opinions naming this issue, 2017–2017
2 sentences

2017Holly v. Montes, 231 Ill. 2d 153, 161-62 (2008).

2017Holly v. Montes, 231 Ill. 2d 153, 161-62 (2008).

22
Revolution Portfolio, LLC v. Bealegreen
illappct · 2002 · cited in 2 Illinois opinions naming this issue, 2016–2016
2 sentences

2016Pursuant to the statute of limitations, a “petition to revive a judgment, as provided by Section 2-1601 of [the] Code, may be filed no later than 20 years next after the date of entry of such judgment.” 735 ILCS 5/13-218 (West 2014); Revolution Portfolio, LLC v. Beale, 332 Ill.

2016Pursuant to the statute of limitations, a “petition to revive a judgment, as provided by Section 2-1601 of [the] Code, may be filed no later than 20 years next after the date of entry of such judgment.” 735 ILCS 5/13-218 (West 2014); Revolution Portfolio, LLC v. Beale, 332 Ill.

22
Moran v. Katsinasgreen
ill · 1959 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011Consequently, the more relevant canon of construction may be the one stating that "where the same, or substantially the same, words or phrases appear in different parts of the same statute they will be given a generally accepted and consistent meaning, where the legislative intent is not clearly expressed to the contrary." Moran v. Katsinas, 16 Ill.2d 169, 174 , 157 N.E.2d 38 (1959).

2011Consequently, the more relevant canon of construction may be the one stating that "where the same, or substantially the same, words or phrases appear in different parts of the same statute they will be given a generally accepted and consistent meaning, where the legislative intent is not clearly expressed to the contrary." Moran v. Katsinas, 16 Ill.2d 169, 174 , 157 N.E.2d 38 (1959).

22
People v. Laubschergreen
ill · 1998 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006Furthermore, criminal or penal statutes are to ‘be strictly construed in favor of the accused, and nothing should be taken by intendment or implication beyond the obvious or literal meaning of the statute.’ People v. Laubscher, 183 Ill. 2d 330, 337 (1998). *** However, if the language of a statute is ambiguous, we may look to tools of interpretation–such as the doctrine of in pari materia–to ascertain the meaning of a provision.” Taylor, 221 Ill. 2d at 162-63 .

2006Furthermore, criminal or penal statutes are to ‘be strictly construed in favor of the accused, and nothing should be taken by intendment or implication beyond the obvious or literal meaning of the statute.’ People v. Laubscher, 183 Ill. 2d 330, 337 (1998). *** However, if the language of a statute is ambiguous, we may look to tools of interpretation — such as the doctrine of in pari materia — to ascertain the meaning of a provision.” Taylor, 221 Ill. 2d at 162-63 .

22
Johnson v. St. Therese Medical Centergreen
illappct · 1998 · cited in 2 Illinois opinions naming this issue, 1999–1999
2 sentences

1999Therese Medical Center, 296 Ill.App.3d 341, 348 , 230 Ill.Dec. 810 , 694 N.E.2d 1088 (1998).

1999Therese Medical Center, 296 Ill.

22
People v. Rinehartgreen
ill · 2012 · cited in 4 Illinois opinions naming this issue, 2012–2012
2 sentences

2012See People v. Rhinehart, 2012 IL 111719, ¶ 26 (recognizing that under the doctrine of in pari materia, two statutes or two parts of one statute must be considered with reference to each other to allow for a “ ‘harmonious’ ” interpretation of the relevant provisions, and words and phrases should be construed with reference to other relevant provisions and not in isolation).

2012Under the doctrine of in pari materia, two statutes, or two parts of one statute concerning the same subject, must be considered together in order to produce a “ ‘harmonious whole.’ ” People v. Rinehart, 2012 IL 111719, ¶ 26 , 962 N.E.2d 444 (quoting Sulser v. Country Mutual Insurance Co., 147 Ill. 2d 548, 555 , 591 N.E.2d 427, 429 (1992)). ¶ 35 We begin with section 6-20(e) of the Liquor Act, which states, “The consumption of alcoholic liquor by any person under 21 years of age is forbidden.” 235 ILCS 5/6-20(e) (West 2010).

14
Girard v. Whitegreen
illappct · 2005 · cited in 4 Illinois opinions naming this issue, 2008–2011
2 sentences

2011E.g., Girard v. White, 356 Ill.App.3d 11, 17 , 292 Ill.Dec. 376 , 826 N.E.2d 517 (2005).

2011E.g., Girard v. White, 356 Ill.App.3d 11, 17 , 292 Ill.Dec. 376 , 826 N.E.2d 517 (2005).

14
General Motors Corp. v. State of Illinois Motor Vehicle Review Boardgreen
ill · 2007 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024General Motors Corp. v. State of Illinois Motor Vehicle Review Board, 224 Ill. 2d 1, 28 (2007). ¶ 33 Moreover, even if we apply the doctrine of in pari materia, the plaintiffs cite no authority holding that a contract between a manufacturer and its affiliate creates a franchise under the Act.

11
People v. Jordangreen
ill · 1984 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024See Jordan, 103 Ill. 2d at 206 . ¶ 27 The majority’s interpretation also fails under the in pari materia doctrine.

11
Miller v. AMERICAN INFERTILITY GROUPgreen
illappct · 2008 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021Miller v. American Infertility Group of Illinois, S.C., 386 Ill.

11
Sulser v. Country Mutual Insurancegreen
ill · 1992 · cited in 1 Illinois opinions naming this issue, 2012–2012
11
Hernon v. EW Corrigan Const. Co.green
ill · 1992 · cited in 1 Illinois opinions naming this issue, 2012–2012
1 sentence

2012Corrigan Construction Co., 149 Ill. 2d 190, 195 (1992). ¶ 24 Under the doctrine of in pari materia, two legislative acts that address the same subject are considered with reference to one another, so that they may be given harmonious effect.

11
Brucker v. Mercolagreen
ill · 2007 · cited in 1 Illinois opinions naming this issue, 2009–2009
11
People v. Mayagreen
ill · 1985 · cited in 1 Illinois opinions naming this issue, 1996–1996
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 (17)

CaseCitedYears
Citizens Opposing Pollution v. Exxonmobil Coal U.S.A. green
ill · 2012
2 sentences

2024Similarly, “[u]nder the doctrine of in pari materia, two legislative acts that address the same subject are considered with reference to one another, so that they may be given harmonious effect.” Citizens Opposing Pollution v. ExxonMobil Coal U.S.A., 2012 IL 111286, ¶ 24 .

2024They assert that First -7- 1-23-0551 American did neither by retaining the TIF note while still trying to collect from the guarantors and, thus, the judgment against them has been satisfied. ¶ 28 To arrive at their desired result, the guarantors construe the relevant UCC provisions regarding accepting collateral as mandatory and apply the doctrine of in pari materia, which views sections of a statute as a whole and gives them “harmonious effect.” Citizens Opposing Pollution v. ExxonMobil Coal U.S.A., 2012 IL 111286, ¶ 24 .

82014–2024
State Farm Mutual Automobile Insurance Company v. Burke green
illappct · 2016
2 sentences

2020Further, under the doctrine of in pari materia, “where different statutes touch on the same or related subject matter, we consider them together so as to render a harmonious result.” State Farm Mutual Automobile Insurance Co. v. Burke, 2016 IL App (2d) 150462, ¶ 39 .

2020Further, under the doctrine of in pari materia, “where different statutes touch on the same or related subject matter, we consider them together so as to render a harmonious result.” State Farm Mutual Automobile Insurance Co. v. Burke, 2016 IL App (2d) 150462, ¶ 39 . ¶ 31 The Board found that Hauber’s death made it impossible to grant him effective relief on his two pending disability pension applications, as Hauber could no longer receive any benefits even if his applications were granted.

52016–2020
People v. Rinehart green
ill · 2012
2 sentences

2012People v. Rinehart, 2012 IL 111719, ¶ 26 , 962 N.E.2d 444 .

2012Under the doctrine of in pari materia, two statutes, or two parts of one statute concerning the same subject, must be considered together in order to produce a “ ‘harmonious whole.’ ” People v. Rinehart, 2012 IL 111719, ¶ 26 , 962 N.E.2d 444 (quoting Sulser v. Country Mutual Insurance Co., 147 Ill. 2d 548, 555 , 591 N.E.2d 427, 429 (1992)). ¶ 35 We begin with section 6-20(e) of the Liquor Act, which states, “The consumption of alcoholic liquor by any person under 21 years of age is forbidden.” 235 ILCS 5/6-20(e) (West 2010).

32012–2012
People v. Hunter green
illappct · 2007
2 sentences

2008Hunter, 376 Ill.

2008Hunter, 376 Ill.

32007–2008
Sperl v. Henry green
ill · 2018
2 sentences

2020“A court may also consider the reason for the statute, the problems it seeks to remedy, the purposes to be achieved, and the consequences of interpreting the statute one way or another.” Sperl v. Henry, 2018 IL 123132, ¶ 23 ; Solon, 236 Ill. 2d at 440-41 . ¶ 33 Applying these principles here, we conclude that the cost of transcripts necessary for an appeal is within the “fees, costs, and charges” that may be waived for indigent litigants, regardless of whether the litigant is represented by counsel under section 5-105.5 or is a self- represented applicant under section 5-105. ¶ 34 We begin by

2020“A court may also consider the reason for the statute, the problems it seeks to remedy, the purposes to be achieved, and the - 13 - 2020 IL App (2d) 200131 consequences of interpreting the statute one way or another.” Sperl v. Henry, 2018 IL 123132, ¶ 23 ; Solon, 236 Ill. 2d at 440-41 . ¶ 33 Applying these principles here, we conclude that the cost of transcripts necessary for an appeal is within the “fees, costs, and charges” that may be waived for indigent litigants, regardless of whether the litigant is represented by counsel under section 5-105.5 or is a self-represented applicant under se

22020–2020
Solon v. Midwest Medical Records Ass'n green
ill · 2010
2 sentences

2020“A court may also consider the reason for the statute, the problems it seeks to remedy, the purposes to be achieved, and the consequences of interpreting the statute one way or another.” Sperl v. Henry, 2018 IL 123132, ¶ 23 ; Solon, 236 Ill. 2d at 440-41 . ¶ 33 Applying these principles here, we conclude that the cost of transcripts necessary for an appeal is within the “fees, costs, and charges” that may be waived for indigent litigants, regardless of whether the litigant is represented by counsel under section 5-105.5 or is a self- represented applicant under section 5-105. ¶ 34 We begin by

2020“A court may also consider the reason for the statute, the problems it seeks to remedy, the purposes to be achieved, and the - 13 - 2020 IL App (2d) 200131 consequences of interpreting the statute one way or another.” Sperl v. Henry, 2018 IL 123132, ¶ 23 ; Solon, 236 Ill. 2d at 440-41 . ¶ 33 Applying these principles here, we conclude that the cost of transcripts necessary for an appeal is within the “fees, costs, and charges” that may be waived for indigent litigants, regardless of whether the litigant is represented by counsel under section 5-105.5 or is a self-represented applicant under se

22020–2020
Gaffney v. Board of Trustees of the Orland Fire Protection District green
ill · 2012
2 sentences

2012In doing so, the question becomes whether a routine traffic stop for speeding qualifies as “an appropriate emergency response.” We hold that it does not. ¶ 29 Our supreme court recently addressed a similar issue in Gaffney v. Board of Trustees of the Orland Fire Protection District, 2012 IL 110012, ¶ 64 , 2012 WL 525459 .

2012In doing so, the question becomes whether a routine traffic stop for speeding qualifies as "an appropriate emergency response." We hold that it does not. ¶ 29 Our supreme court recently addressed a similar issue in Gaffney v. Board of Trustees of the Orland Fire Protection District, 2012 IL 110012, ¶ 64 , 360 Ill.Dec. 549, 563 , 969 N.E.2d 359, 373 .

22012–2012
Land v. Board of Educ. of City of Chicago green
illappct · 2001
2 sentences

2002The appellate court, in its effort to give effect to all of the relevant sections of the School Code, invoked the doctrine of in pari materia . 325 Ill.

2002The appellate court, in its effort to give effect to all of the relevant sections of the School Code, invoked the doctrine of in pari materia. 325 Ill.

22002–2002
Wal-Mart Stores, Inc. v. Industrial Commission green
illappct · 2001
1 sentence

2022See 1946 Buick, 127 Ill. 2d at 377 ; Wal-Mart, 324 Ill.

12022–2022
In re Marriage of Main green
illappct · 2020
1 sentence

2020“A court may also consider the reason for the statute, the problems it seeks to remedy, the purposes to be achieved, and the - 13 - 2020 IL App (2d) 200131 consequences of interpreting the statute one way or another.” Sperl v. Henry, 2018 IL 123132, ¶ 23 ; Solon, 236 Ill. 2d at 440-41 . ¶ 33 Applying these principles here, we conclude that the cost of transcripts necessary for an appeal is within the “fees, costs, and charges” that may be waived for indigent litigants, regardless of whether the litigant is represented by counsel under section 5-105.5 or is a self-represented applicant under se

12020–2020
People v. Harris green
illappct · 2014
1 sentence

2017Section 5-6-4(j) states: “(j) When an offender is re-sentenced after revocation of probation that was imposed in combination with a sentence of imprisonment for the same offense, the aggregate of the sentences may not exceed the maximum term authorized under Article 4.5 of Chapter V.” “[U]nder the doctrine of in pari materia, two sections of a statute dealing with the same subject will be considered with reference to one another to give them harmonious effect.” People v. Harris, 2013 IL App (1st) 110309, ¶ 13 .

12017–2017
People v. Schneider green
illappct · 2010
12012–2012
Gaffney v. ORLAND FIRE PROTECTION DIST. green
ill · 2012
12012–2012
Maksym v. Board of Election Commissioners green
illappct · 2011
12011–2011
Rawles v. Hartman green
illappct · 1988
11992–1992
People v. One 1985 Chevrolet Camaro green
illappct · 1986
11989–1989
Douglas v. Daniels green
illappct · 1978
11979–1979

Statutes the citing opinions construe

IL § 735 ILCS 5/2-619 (9) IL § 735 ILCS 5/2-1005 (8) IL § 735 ILCS 5/2-615 (6) IL § 705 ILCS 105/27.2a (5) IL § 745 ILCS 10/3-106 (5) IL § 745 ILCS 10/3-107 (5) IL § 765 ILCS 605/9 (5) IL § 415 ILCS 5/21 (4) IL § 625 ILCS 5/11-501 (4) IL § 730 ILCS 5/5-8-1 (4) IL § 750 ILCS 5/101 (4) IL § 735 ILCS 5/22-105 (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

TX 109 (1952–2026) IL 98 (1979–2026) MI 77 (1988–2026) FL 43 (2005–2025) OH 40 (1922–2026) MN 11 (1994–2017) MS 10 (1989–2023) AZ 10 (1988–2025) WV 8 (1986–2024) MO 8 (2016–2022) PA 8 (2010–2023) KY 6 (1920–2019) NJ 5 (1975–2022) HI 4 (2006–2025) MD 4 (1986–2025) IA 4 (1995–2007) CA 3 (1963–1988) WI 3 (1987–2020) CO 3 (2009–2013) IN 3 (1956–2018) VA 3 (2023–2025) NV 2 (2022–2022) GA 2 (2015–2016) ID 2 (2014–2023) NC 2 (1925–2007) AL 2 (1987–2026) TN 2 (2015–2018) CT 2 (1983–1999)

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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