false-light claim (Illinois) · Go Syfert
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false-light claim in Illinois

12 Illinois opinions name it 1 courts 1990–2024 2 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 (5)

CaseFollowedCited
Benton v. Little League Baseball, Inc.green
illappct · 2020 · cited in 2 Illinois opinions naming this issue, 2023–2024
2 sentences

2024See Benton, 2020 IL App (1st) 190549, ¶ 83 ; Chang Hyun Moon v. Kang Jun Liu, 2015 IL App (1st) 143606, ¶ 17 ; Schaffer v. Zekman, 196 Ill.

2023See Benton v. Little League Baseball, Incorporated, 2020 IL App (1st) 190549 , ¶ 89; Kapotas, 2015 IL App (1st) 140534, ¶ 78 ; Harte v. Chicago Council of Lawyers, 220 Ill.

22
Bryson v. News America Publications, Inc.green
ill · 1996 · cited in 2 Illinois opinions naming this issue, 2007–2007
2 sentences

2007Bryson v. News America Publications, Inc., 174 Ill. 2d 77, 106 , 672 N.E.2d 1207, 1223 (1996) (finding that the false-light claim related back to the timely filed defamation claim based on the same transaction or occurrence).

2007Bryson v. News America Publications, Inc., 174 Ill. 2d 77, 106 , 672 N.E.2d 1207, 1223 (1996) (finding that the false-light claim related back to the timely filed defamation claim based on the same transaction or occurrence).

22
Schaffer v. Zekmangreen
illappct · 1990 · cited in 2 Illinois opinions naming this issue, 1996–2024
2 sentences

2024Id. at 733-34 . ¶ 48 The court began the discussion by presenting the elements of a false-light claim as stated in Lovgren.

2024It noted that a false-light claim, “although closely related to defamation, protects one’s interest in being let alone from offensive publicity.” Id.

12
Harte v. Chicago Council of Lawyersgreen
illappct · 1991 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023See Benton v. Little League Baseball, Incorporated, 2020 IL App (1st) 190549 , ¶ 89; Kapotas, 2015 IL App (1st) 140534, ¶ 78 ; Harte v. Chicago Council of Lawyers, 220 Ill.

11
Weinstein v. Bullickgreen
paed · 1993 · cited in 1 Illinois opinions naming this issue, 1996–1996
2 sentences

1996Weinstein v. Bullick, 827 F. Supp. 1193, 1202 (E.D.

1996Weinstein v. Bullick, 827 F.Supp. 1193, 1202 (E.D.Pa.1993); Schaffer, 196 Ill.App.3d at 734 , 143 Ill.Dec. 916 , 554 N.E.2d 988 .

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 (7)

CaseCitedYears
Kurczaba v. Pollock green
illappct · 2000
2 sentences

2002Kurczaba v. Pollock, 318 Ill.

2002Kurczaba v. Pollock , 318 Ill.

42001–2002
Lovgren v. Citizens First National Bank green
ill · 1989
2 sentences

2024Lovgren, 126 Ill. 2d at 418 .

2001Lovgren v. Citizens First National Bank of Princeton , 126 Ill. 2d 411 , 534 N.E.2d 987 (1989).

32001–2024
Sarmont v. DeWitt green
illappct · 2024
2 sentences

2024Plaintiff contends the court erred in determining that (1) “forensic 2024 IL App (2d) 230239 investigator[ ]” fees, which plaintiff allegedly incurred “to defend himself,” are not special damages for purposes of his defamation claim and (2) plaintiff must plead special damages to state a false-light claim.

2024Defendants argued that the requirement to plead special damages in a defamation 2 The court noted that, if it were to consider the issue of “actual malice” under section 2- 619, the court could “look at [DeWitt’s] affidavit, but it’s sort of premature because it’s contradicting the allegations that [DeWitt] did it in such a way that was to let everybody know in the church that he was attributed to this e-mail.” -7- 2024 IL App (2d) 230239 per quod action applies equally to a false-light claim that is based on a defamatory per quod statement.

12024–2024
Moon v. Liu green
illappct · 2016
1 sentence

2024See Benton, 2020 IL App (1st) 190549, ¶ 83 ; Chang Hyun Moon v. Kang Jun Liu, 2015 IL App (1st) 143606, ¶ 17 ; Schaffer v. Zekman, 196 Ill.

12024–2024
Kapotas v. Better Government Association green
illappct · 2015
1 sentence

2023See Benton v. Little League Baseball, Incorporated, 2020 IL App (1st) 190549 , ¶ 89; Kapotas, 2015 IL App (1st) 140534, ¶ 78 ; Harte v. Chicago Council of Lawyers, 220 Ill.

12023–2023
Fellows v. National Enquirer, Inc. green
cal · 1986
2 sentences

1990Pa. 1980), 500 F Supp. 1081, 1088 ; Restatement (Second) of Torts §652E, comment e, at 399.) In Fellows v. National Enquirer, Inc. (1986), 42 Cal. 3d 234, 251 , 721 P.2d 97, 108 , 228 Cal. Rptr. 215, 227 , the supreme court of California held that, whenever a claim for false-light invasion of privacy was based on language that was defamatory only by reference to extrinsic facts, pleading and proof of special damages were required. 3 In considering the applicability of the special damages requirement to a false-light claim, the Fellows court acknowledged the evolution of restrictions and limita

1990Pa. 1980), 500 F Supp. 1081, 1088 ; Restatement (Second) of Torts §652E, comment e, at 399.) In Fellows v. National Enquirer, Inc. (1986), 42 Cal. 3d 234, 251 , 721 P.2d 97, 108 , 228 Cal. Rptr. 215, 227 , the supreme court of California held that, whenever a claim for false-light invasion of privacy was based on language that was defamatory only by reference to extrinsic facts, pleading and proof of special damages were required. 3 In considering the applicability of the special damages requirement to a false-light claim, the Fellows court acknowledged the evolution of restrictions and limita

11990–1990
Fogel v. Forbes, Inc. green
paed · 1980
1 sentence

1990Pa. 1980), 500 F Supp. 1081, 1088 ; Restatement (Second) of Torts §652E, comment e, at 399.) In Fellows v. National Enquirer, Inc. (1986), 42 Cal. 3d 234, 251 , 721 P.2d 97, 108 , 228 Cal. Rptr. 215, 227 , the supreme court of California held that, whenever a claim for false-light invasion of privacy was based on language that was defamatory only by reference to extrinsic facts, pleading and proof of special damages were required. 3 In considering the applicability of the special damages requirement to a false-light claim, the Fellows court acknowledged the evolution of restrictions and limita

11990–1990

Statutes the citing opinions construe

IL § 735 ILCS 5/2-615 (4) IL § 735 ILCS 5/2-619 (4)

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

IL 12 (1990–2024) OH 5 (2007–2026) MI 4 (2014–2024) AL 4 (2003–2007) NJ 4 (1988–2025) HI 3 (2009–2018) RI 2 (2002–2004) OR 2 (1997–1998) CA 2 (1987–2015)

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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