severed claim (Illinois) · Go Syfert
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severed claim in Illinois

12 Illinois opinions name it 2 courts 1986–2025 1 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 (1)

CaseFollowedCited
Carter v. CHICAGO & ILL. MID. RY. CO.green
ill · 1988 · cited in 10 Illinois opinions naming this issue, 1988–2025
2 sentences

2025The court ruled, however, that in a case involving multiple - 14 - No. 1-23-2508 parties or claims, if a court has not made a Rule 304(a) finding, the dismissal of a claim is immediately appealable only if the court “clearly and unequivocally” states in its severance order “that the claim, counterclaim or the party has indeed been severed (in the narrow sense of that word) and that the severed claim, counterclaim or party shall proceed thereafter separate from the other claims, counterclaims or parties to the case.” (Emphasis in original.) Id. at 307-08 .

2015Co., 119 Ill. 2d 296, 308 (1988) (holding that severance might make orders in the severed claim appealable).

510

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 (5)

CaseCitedYears
Santana v. Zipperstein green
illappct · 1986
2 sentences

2015Tsevis’s notice of appeal cites Santana v. Zipperstein, 142 Ill.

2015Tsevis’s notice of appeal cites Santana v. Zipperstein, 142 Ill.

22015–2015
Northtown Warehouse & Transportation Co. v. Transamerica Insurance neutral
ill · 1986
2 sentences

1990(Northtown Warehouse & Transportation Co. v. Transamerica Insurance Co. (1986), 111 Ill. 2d 532 , 490 N.E.2d 1268 .) However, the supreme court has explained: “[T]he trial court, in its severance order, [must] clearly and unequivocally statef] that the claim, counterclaim or the party has indeed been severed (in the narrow sense of that word) and that the severed claim, counterclaim or party shall proceed thereafter separate from the other claims, counterclaims or parties to the case.” (Emphasis in original.) (Carter v. Chicago & Illinois Midland R.R.

1990(Northtown Warehouse & Transportation Co. v. Transamerica Insurance Co. (1986), 111 Ill. 2d 532 , 490 N.E.2d 1268 .) However, the supreme court has explained: “[T]he trial court, in its severance order, [must] clearly and unequivocally statef] that the claim, counterclaim or the party has indeed been severed (in the narrow sense of that word) and that the severed claim, counterclaim or party shall proceed thereafter separate from the other claims, counterclaims or parties to the case.” (Emphasis in original.) (Carter v. Chicago & Illinois Midland R.R.

21987–1990
Salyers v. BD. OF GOVERNORS OF STATE COLLEGES AND UNIVERSITIES green
illappct · 1979
2 sentences

1987In Sadler v. County of Cook the court, when considering the issue of the appealability of severed claims under Supreme Court Rule 304(a) (107 Ill. 2d R. 304(a)), found that a severed claim or cause of action results in a separate trial for purposes of the Rule, rather than a separate action, as had been earlier determined in Salyers v. Board of Governors (1979), 69 Ill.

1987App. 3d 356, 358 , 387 N.E.2d 1129 .

11987–1987
Spencer, White & Prentis Incorporated of Connecticut v. Pfizer Incorporated green
ca2 · 1974
1 sentence

1986(Hebel v. Ebersole (7th Cir. 1976), 543 F.2d 14 , 17.) For example, in Spencer, White & Prentis Inc. v. Pfizer Inc. (2d Cir. 1974), 498 F.2d 358 , a contractor sued to recover an unpaid balance of $59,912.50 due on a construction agreement.

11986–1986
Hebel v. Ebersole green
ca1 · 1976
1 sentence

1986(Hebel v. Ebersole (7th Cir. 1976), 543 F.2d 14 , 17.) For example, in Spencer, White & Prentis Inc. v. Pfizer Inc. (2d Cir. 1974), 498 F.2d 358 , a contractor sued to recover an unpaid balance of $59,912.50 due on a construction agreement.

11986–1986

Where else courts name it

TX 142 (1981–2026) IL 12 (1986–2025) AL 4 (1988–2017) WA 3 (2002–2020) CA 2 (2013–2022)

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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