12 Illinois opinions name it 2 courts 1991–2024 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.
| Case | Followed | Cited |
|---|---|---|
County of Cook v. Phillip Morris, Inc.green2 sentences2009Therefore, one manner of determining proximate cause is through the remoteness doctrine or “direct-injury” test, which holds that there must be “ ‘some direct relation between the injury asserted and the injurious conduct alleged.’ ” County of Cook, 353 Ill. 2005App. 3d 55 , 817 N.E.2d 1039 (2004), this court held that the remoteness doctrine, also referred to as the direct injury test, barred the county’s action seeking damages against tobacco manufacturers for the cost of treating smokers. | 1 | 4 |
People v. Martinezgreen1 sentence2023See Martinez, 2021 IL App (1st) 182553, ¶ 46 ; Barnes, 2017 IL App (1st) 143902, ¶ 49 . ¶ 23 Nevertheless, defendant argues that the trial court’s remoteness analysis ignored the context of Commander Bauer and his rank within the Chicago Police Department. | 1 | 1 |
Kraft Chemical Co. v. Illinois Bell Telephone Co.green1 sentence2004See Kraft Chemical Co. v. Illinois Bell Telephone Co., 240 Ill. | 1 | 1 |
Blue Cross & Blue Shield of New Jersey, Inc. v. Philip Morris, Inc.green1 sentence2004See City & County of San Francisco v. Philip Morris, Inc., No. C 96 — 2090 (March 3, 1998); see also Blue Cross & Blue Shield of New Jersey, Inc., 36 F. Supp. 2d 560 (rejecting remoteness doctrine where plaintiffs alleged injuries stemming from their own reliance on defendants’ misrepresentations). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
People v. Gibbs
green
2 sentences2018Although the court in Ellis was discussing the evidence under both the Montgomery standard, which has an explicit 10-year limitation period, and the Lynch standard, there is nothing in the decision to suggest that the remoteness analysis applied solely to the evidence under Montgomery, as defendant suggests, and not under both standards. - 10 - ¶ 51 Defendant, nonetheless, relies on People v. Gibbs, 2016 IL App (1st) 140785 , ¶ 34, where this court affirmed the trial court’s decision to allow the defendant to present evidence of the victim’s 14-year-old conviction for domestic violence via sti 2017Although the court in Ellis was discussing the evidence under both the Montgomery standard, which has an explicit 10-year limitation period, and the Lynch standard, there is nothing in the decision to suggest that the remoteness analysis applied solely to the evidence under Montgomery , as defendant suggests, and not under both standards. ¶ 51 Defendant, nonetheless, relies on People v. Gibbs , 2016 IL App (1st) 140785 , ¶ 34, 404 Ill.Dec. 137 , 55 N.E.3d 233 , where this court affirmed the trial court's decision to allow the defendant to present evidence of the victim's 14-year-old conviction | 2 | 2017–2018 |
Holmes v. Securities Investor Protection Corporation
green
2 sentences2009App. 3d at 60 , quoting Holmes v. Securities Investor Protection Corp., 503 U.S. 258, 268 , 117 L. 2009App. 3d at 60 , quoting Holmes v. Securities Investor Protection Corp., 503 U.S. 258, 268 , 117 L. | 2 | 2004–2009 |
City of Cincinnati v. Beretta U.S.A. Corp.
green
2 sentences2003City of Cincinnati, 95 Ohio St.3d at 417 , 768 N.E.2d at 1140. 2003City of Cincinnati, 95 Ohio St. 3d at 417 , 768 N.E.2d at 1140. | 2 | 2002–2003 |
In re Commonwealth Edison Co. Illinois Consumer Fraud Litigation
green
1 sentence2024Legal cause is essentially a question of foreseeability: a negligent act is a proximate cause of an injury if the injury is of a type which a reasonable [person] would see as a likely result of [their] conduct.” (Internal citations and quotation marks omitted.) ComEd, 2023 IL App (1st) 220105, ¶ 23 . ¶ 60 “One way in which the concept of proximate cause operates is through the remoteness doctrine, which is sometimes called the direct-injury test. | 1 | 2024–2024 |
People v. Barnes
green
1 sentence2023See Martinez, 2021 IL App (1st) 182553, ¶ 46 ; Barnes, 2017 IL App (1st) 143902, ¶ 49 . ¶ 23 Nevertheless, defendant argues that the trial court’s remoteness analysis ignored the context of Commander Bauer and his rank within the Chicago Police Department. | 1 | 2023–2023 |
Arangold Corp. v. Zehnder
green
1 sentence2004The plaintiffs’ reliance on Arangold Corp. v. Zehnder, 329 Ill. | 1 | 2004–2004 |
Shannon v. Boise Cascade
green
1 sentence2004In Shannon v. Boise Cascade, 328 Ill. | 1 | 2004–2004 |
Dundee Cement Company v. Chemical Laboratories, Inc.
green
1 sentence1992(Dundee Cement Co. v. Chemical Laboratories, Inc. (7th Cir. 1983), 712 F.2d 1166 .) The doctrine of remoteness is not based upon a factual inquiry to determine whether the damages claimed were foreseeable or whether there was proximate cause; rather, it is a legal doctrine incorporating public policy considerations. | 1 | 1992–1992 |
People v. Ward
green
1 sentence1991The defendant observes that this court has recognized that “[a] trial court may reject offered evidence on grounds of irrelevancy if it has little probative value due to its remoteness.” (People v. Ward (1984), 101 Ill. 2d 443, 455 .) We note, however, that the trial court here did not reject the offered evidence as too remote. | 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.