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12 Illinois opinions name it 2 courts 1985–2025 3 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 |
|---|---|---|
Snelson v. Kammgreen2 sentences2025There is no dispute that Michael did not make an offer of proof. ¶ 25 “When a motion in limine is granted, the key to saving for review an error in the exclusion of evidence is an adequate offer of proof in the trial court.” Snelson v. Kamm, 204 Ill. 2d 1, 23 (2003). 2025There is no dispute that Michael did not make an offer of proof. -7- ¶ 25 “When a motion in limine is granted, the key to saving for review an error in the exclusion of evidence is an adequate offer of proof in the trial court.” Snelson v. Kamm, 204 Ill. 2d 1, 23 (2003). | 2 | 2 |
State Farm Mutual Insurance v. Ellisongreen2 sentences2014State Farm Mutual Insurance Co. v. Ellison, 354 Ill. 2014State Farm Mutual Insurance Co. v. Ellison, 354 Ill. | 2 | 2 |
First Capitol Mortgage Corp. v. Talandis Construction Corp.green2 sentences2003See Talandis, 63 Ill. 2d at 133 , 345 N.E.2d at 495 . 2003See Talandis, 63 Ill. 2d at 133 , 345 N.E.2d at 495 . | 2 | 2 |
In Re Marriage of Burbridgegreen1 sentence2025In re Marriage of Burbridge, 317 Ill. App. 3d 190, 193 (2000) (trial court abused its discretion in dismissing incarcerated father’s petition to modify child support without holding an evidentiary hearing or making factual findings). | 1 | 1 |
Corral v. Mervis Industries, Inc.green1 sentence2019App. 3d 780, 783 (2011) (it is the appellant’s burden to provide this court “with a sufficiently complete record to allow for 1 It is unclear from the record petitioner submitted or his “Pro Se Motion to Limit Record on Appeal of Child Support Order to Relevant Portion of Entire Divorce Court Record” whether the document petitioner titled “Catherine’s motion to set arrearage” filed on March 8, 2017, was the subject of the court’s May 31, 2018, order. -7- 1-18-1649 meaningful appellate review”); Corral v. Mervis Industries, Inc., 217 Ill. 2d 144, 155 (2005) (stating that it was unclear how the | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In re The Marriage of Eckersall
green
2 sentences2015A divided panel of the appellate court did not address Catherine’s substantive issues and dismissed the appeal for lack of jurisdiction, finding that the order was not an injunction and not appealable under Rule 307(a)(1). 2014 IL App (1st) 132223 , ¶ 31. 2015A divided panel of the appellate court did not address Catherine’s substantive issues and dismissed the appeal for lack of jurisdiction, finding that the order was not an injunction and not appealable under Rule 307(a)(1). 2014 IL App (1st) 132223 , ¶ 31. | 3 | 2015–2015 |
In re Estate of McDonald
green
2 sentences2025Because Michael did not make an offer of proof, we cannot evaluate his claim that the trial court granting Catherine’s motion in limine “prejudiced his property award in the dissolution judgment.” We cannot tell whether he would have been able to establish that any of the 13 accounts at issue were nonmarital property, and, if so, which ones. -9- ¶ 30 We acknowledge that “an offer of proof need not be made if it is clear that the trial court understood the nature and character of the evidence that would have been offered.” In re Estate of McDonald, 2022 IL 126956, ¶ 86 . 2025Because Michael did not make an offer of proof, we cannot evaluate his claim that the trial court granting Catherine’s motion in limine “prejudiced his property award in the dissolution judgment.” We cannot tell whether he would have been able to establish that any of the 13 accounts at issue were nonmarital property, and, if so, which ones. ¶ 30 We acknowledge that “an offer of proof need not be made if it is clear that the trial court understood the nature and character of the evidence that would have been offered.” In re Estate of McDonald, 2022 IL 126956, ¶ 86 . | 2 | 2025–2025 |
In Re Marriage of Sorenson
green
2 sentences1985App. 3d 967 , 469 N.E.2d 440 . 1985In an order dated January 31, 1985, Judge Kaufman found that he was confident of his ability to proceed in the manner requested in Catherine’s motion, but he held that he was absolutely precluded from doing so because of the case of In re Marriage of Sorenson (1984), 127 Ill. | 1 | 1985–1985 |
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.