common-law negligence claim (Illinois) · Go Syfert
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common-law negligence claim in Illinois

13 Illinois opinions name it 2 courts 1996–2026 5 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 (9)

CaseFollowedCited
Williams v. Manchestergreen
ill · 2008 · cited in 2 Illinois opinions naming this issue, 2018–2019
2 sentences

2019See Williams v. Manchester, 228 Ill. 2d 404, 415 (2008) (the elements of a wrongful death claim are identical to those of a common-law negligence claim); Kirk v. Michael Reese Hospital & Medical Center, 117 Ill. 2d 507, 525 (1987). ¶ 34 The proximate cause element is a factual question for the jury to decide and has two components: cause in fact and legal cause.

2018See Williams v. Manchester , 228 Ill. 2d 404 , 415, 320 Ill.Dec. 784 , 888 N.E.2d 1 (2008) (the elements of a wrongful death claim are identical to those of a common-law negligence claim); Kirk v. Michael Reese Hospital & Medical Center , 117 Ill. 2d 507 , 525, 111 Ill.Dec. 944 , 513 N.E.2d 387 (1987). ¶ 34 The proximate cause element is a factual question for the jury to decide and has two components: cause in fact and legal cause.

22
City of Columbus v. Ours Garage & Wrecker Service, Inc.green
scotus · 2002 · cited in 2 Illinois opinions naming this issue, 2025–2025
2 sentences

2025See Columbus, 536 U.S. at 438 ; Haage, 2021 IL 125918, ¶ 72 .

2025Columbus, 536 U.S. at 438 ; Haage, 2021 IL 125918, ¶ 72 .

12
Kirk v. Michael Reese Hospital & Medical Centergreen
ill · 1987 · cited in 2 Illinois opinions naming this issue, 2018–2019
2 sentences

2019See Williams v. Manchester, 228 Ill. 2d 404, 415 (2008) (the elements of a wrongful death claim are identical to those of a common-law negligence claim); Kirk v. Michael Reese Hospital & Medical Center, 117 Ill. 2d 507, 525 (1987). ¶ 34 The proximate cause element is a factual question for the jury to decide and has two components: cause in fact and legal cause.

2018See Williams v. Manchester , 228 Ill. 2d 404 , 415, 320 Ill.Dec. 784 , 888 N.E.2d 1 (2008) (the elements of a wrongful death claim are identical to those of a common-law negligence claim); Kirk v. Michael Reese Hospital & Medical Center , 117 Ill. 2d 507 , 525, 111 Ill.Dec. 944 , 513 N.E.2d 387 (1987). ¶ 34 The proximate cause element is a factual question for the jury to decide and has two components: cause in fact and legal cause.

12
Klitzka Ex Rel. Teutonico v. Helliosgreen
illappct · 2004 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026Teutonico v. Hellios, 348 Ill.

11
State Farm Fire and Casualty Company v. Welbornegreen
illappct · 2017 · cited in 1 Illinois opinions naming this issue, 2022–2022
1 sentence

2022See State Farm Fire & Casualty Co. v. Welbourne, 2017 IL App (3d) 160231, ¶ 16 , 85 N.E.3d 561 (“Under negligence law, the standard of care required of a defendant in an ordinary negligence case is to act as an ordinarily careful person or reasonably prudent person would act under similar circumstances.”). ¶ 58 On the other hand, section 305.20 of Title 83, at issue in this case, adopts the NESC’s Rule 232, which provides an array of tables for utility companies to use to determine the proper height at which a specific powerline needs to be maintained dependent upon atmospheric conditions, loc

11
Leonardi v. Loyola University of Chicagogreen
ill · 1995 · cited in 1 Illinois opinions naming this issue, 2014–2014
1 sentence

2014Leonardi v. Loyola University of Chicago, 168 Ill. 2d 83, 97 (1995). 4 It further terminated the Forest Preserve District of Kane County as a respondent in discovery. -6- ¶ 20 To prevail on a common-law negligence claim, a plaintiff must establish that the defendant owed a duty, that the defendant breached that duty, and that the defendant’s breach was the proximate cause of injury to the plaintiff.

11
Lucas v. Kriskagreen
illappct · 1988 · cited in 1 Illinois opinions naming this issue, 2014–2014
1 sentence

2014Lucas, 168 Ill.

11
GOENNENWEIN BY GOENNENWEIN v. Rasofgreen
illappct · 1998 · cited in 1 Illinois opinions naming this issue, 2014–2014
1 sentence

2014The court affirmed the dismissal of the common-law negligence claim because "plaintiff failed to come forward with evidence to raise an issue of fact as to defendant [premises owner]'s knowledge of the dog's alleged dangerousness." Goennenwein, 296 Ill.

11
Krywin v. Chicago Transit Authoritygreen
ill · 2010 · cited in 1 Illinois opinions naming this issue, 2014–2014
1 sentence

2014Krywin v. Chicago Transit Authority, 238 Ill. 2d 215, 225 (2010).

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
Haage v. Zavala green
ill · 2021
2 sentences

2025See Columbus, 536 U.S. at 438 ; Haage, 2021 IL 125918, ¶ 72 .

2025Columbus, 536 U.S. at 438 ; Haage, 2021 IL 125918, ¶ 72 .

22025–2025
Hooper v. County of Cook green
illappct · 2006
2 sentences

2019Turcios v. The DeBruler Co., 2015 IL 117962, ¶ 23 ; -8- Hooper, 366 Ill.

2018Turcios v. The DeBruler Co. , 2015 IL 117962 , ¶ 23, 392 Ill.Dec. 541 , 32 N.E.3d 1117 ; Hooper , 366 Ill.

22018–2019
Turcios v. The DeBruler Company green
ill · 2015
2 sentences

2019Turcios v. The DeBruler Co., 2015 IL 117962, ¶ 23 ; -8- Hooper, 366 Ill.

2018Turcios v. The DeBruler Co. , 2015 IL 117962 , ¶ 23, 392 Ill.Dec. 541 , 32 N.E.3d 1117 ; Hooper , 366 Ill.

22018–2019
Abbasi Ex Rel. Abbasi v. Paraskevoulakos green
ill · 1999
2 sentences

2006Abassi, 187 Ill. 2d at 396 , 718 N.E.2d at 186 .

2006Abassi, 187 Ill. 2d at 396 , 718 N.E.2d at 186 .

22006–2006
Stanko v. Zilien green
illappct · 1961
1 sentence

2021Id. at 366 .

12021–2021
Severson v. Ring green
illappct · 1993
1 sentence

2014Severson, 244 Ill.

12014–2014
Kuehn v. Edward Rose & Sons neutral
michctapp · 1991
2 sentences

2001After rejecting a claim based on Michigan's dramshop act, the court considered the plaintiff's common-law negligence claim and held that "liability for negligently furnishing alcohol does not extend to social hosts who serve alcohol to adults who subsequently injure third parties." Kuehn , 189 Mich. App. at 290 , 472 N.W.2d at 60 .

2001After rejecting a claim based on Michigan's dramshop act, the court considered the plaintiff's common-law negligence claim and held that "liability for negligently furnishing alcohol does not extend to social hosts who serve alcohol to adults who subsequently injure third parties." Kuehn , 189 Mich. App. at 290 , 472 N.W.2d at 60 .

12001–2001
Loomis v. Granny's Rocker Nite Club green
illappct · 1993
1 sentence

1996Loomis v. Granny’s Rocker Nite Club, 250 Ill.

11996–1996

Statutes the citing opinions construe

IL § 740 ILCS 180/1 (4) 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 80 (1989–2026) OR 43 (1985–2025) TX 25 (1994–2026) WI 13 (1992–2026) IL 13 (1996–2026) OH 9 (1988–2020) CT 8 (1995–2025) AZ 5 (2012–2025) KY 5 (2014–2025) MN 5 (1980–2026) MI 4 (1988–2020) NM 4 (1989–2016) WA 3 (1978–2008) DE 2 (2024–2024) TN 2 (2001–2002) GA 2 (2013–2020) NC 2 (2022–2022)

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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