10 Illinois opinions name it 2 courts 2020–2026 7 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 |
|---|---|---|
Ryan v. Fox Television Stations, Inc.green2 sentences2020See Ryan, 2012 IL App (1st) 120005, ¶ 23 . 2020Ryan, 2012 IL App (1st) 120005, ¶ 22 . | 3 | 3 |
Chicago Regional Council of Carpenters v. Jursichgreen2 sentences2020See Chicago Regional Council of Carpenters v. Jursich, 2013 IL App (1st) 113279, ¶ 20 . 2020See Chicago Regional Council of Carpenters v. Jursich, 2013 IL App (1st) 113279, ¶ 20 . | 3 | 3 |
Vickers v. Abbott Laboratoriesgreen2 sentences2020To support this - 21 - No. 1-19-1819 claim, defendant cites Ulm v. Memorial Medical Center, 2012 IL App (4th) 110421, ¶ 42 , Vickers v. Abbot Labs, 308 Ill. 2020Specifically, defendant cites Ulm v. Memorial Medical Center, 2012 IL App (4th) 110421, ¶ 42 , Vickers v. Abbot Labs, 308 Ill. | 3 | 3 |
Dipietro v. GATX Corp.green2 sentences2026Younge v. Cushman & Wakefield, Inc., 2024 IL App (1st) 221524-U, ¶115 (although “wrongful,” defendants’ alleged inclusion of false information in plaintiff’s performance improvement plan to hasten his departure from the company did not rise to the level of outrageousness to support an IIED claim); DiPietro, 2020 IL App (1st) 192196, ¶ 58 (allegations that plaintiff’s manager fabricated plaintiff’s performance deficiencies before firing her, even if true, did not “cross the line into ‘extreme and outrageous,’ ‘outside all bounds of decency,’ or ‘truly egregious.’ ”). 2026Younge v. Cushman & Wakefield, Inc., 2024 IL App (1st) 221524-U, ¶115 (although “wrongful,” defendants’ alleged inclusion of false information in plaintiff’s performance improvement plan to hasten his departure from the company did not rise to the level of outrageousness to support an IIED claim); DiPietro, 2020 IL App (1st) 192196, ¶ 58 (allegations that plaintiff’s manager fabricated plaintiff’s performance deficiencies before firing her, even if true, did not “cross the line into ‘extreme and outrageous,’ ‘outside all bounds of decency,’ or ‘truly egregious.’ ”). | 2 | 2 |
Feltmeier v. Feltmeiergreen2 sentences2026Feltmeier v. Feltmeier, 207 Ill. 2d 263, 269 (2003). ¶ 35 Ervin’s first amended complaint alleged that the “extreme and intolerable” conduct by Straw was her “refusal to honor Fleming’s Power of Attorney and Advance Health Care Directive,” and her failure to notify Fleming’s family of the court proceedings. 2026Feltmeier v. Feltmeier, 207 Ill. 2d 263, 269 (2003). ¶ 35 Ervin’s first amended complaint alleged that the “extreme and intolerable” conduct by Straw was her “refusal to honor Fleming’s Power of Attorney and Advance Health Care Directive,” and her failure to notify Fleming’s family of the court proceedings. | 2 | 2 |
Chadha v. North Park Elementary School Associationgreen2 sentences2020See Chadha, 2018 IL App (1st) 171958, ¶ 98 . 2020See Chadha, 2018 IL App (1st) 171958, ¶ 98 . | 2 | 2 |
Ulm v. Memorial Medical Centergreen2 sentences2024See DiPietro, 2020 IL App (1st) 192196 , ¶ 52; see also Ulm v. Memorial Medical Center, 2012 IL App (4th) 110421, ¶ 46 (although the “unexpected deterioration of an employment relationship is understandably stressful for an employee”, “no conduct alleged of defendant [employer] would provoke in an ordinary person the kind of disdainful response that defines extreme and outrageous conduct within the employment relationship.”) As we do not find evidence from which Younge can establish the elements of IIED, we affirm the dismissal of count II. ¶ 116 There Is a Triable Issue of Fact Regarding Negl 2024See DiPietro, 2020 IL App (1st) 192196 , ¶ 52; see also Ulm v. Memorial Medical Center, 2012 IL App (4th) 110421, ¶ 46 (although the “unexpected deterioration of an employment relationship is understandably stressful for an employee”, “no conduct alleged of defendant [employer] would provoke in an ordinary person the kind of disdainful response that defines extreme and outrageous conduct within the employment relationship.”) As we do not find evidence from which Younge can establish the elements of IIED, we affirm the dismissal of count II. ¶ 116 There Is a Triable Issue of Fact Regarding Negl | 1 | 4 |
Duffy v. Orlan Brook Condominium Owners' Associationgreen2 sentences2026See Duffy, 2012 IL App (1st) 113577, ¶ 36 (a plaintiff must establish that the defendant “intended or recklessly disregarded the probability that the conduct would cause the plaintiff to suffer emotional distress”). 2026See Duffy, 2012 IL App (1st) 113577, ¶ 36 (a plaintiff must establish that the defendant “intended or recklessly disregarded the probability that the conduct would cause the plaintiff to suffer emotional distress”). | 1 | 1 |
Prakash v. Parulekargreen2 sentences2024See Prakash, 2020 IL App (1st) 191819 , ¶ 51. - 11 - 1-22-1046 The emotions and effects she experienced—stress, nervousness, discomfort, sadness, loss of sleep, and loss of focus at work—are, for purposes of an IIED claim, merely trivial injuries. 2024See Prakash, 2020 IL App (1st) 191819 , ¶ 51. - 11 - 1-22-1046 The emotions and effects she experienced—stress, nervousness, discomfort, sadness, loss of sleep, and loss of focus at work—are, for purposes of an IIED claim, merely trivial injuries. | 1 | 1 |
Benton v. Little League Baseball, Inc.green2 sentences2024Rather, as explained in Benton: “[L]iability only attaches ‘where the conduct has been so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community’ and where the distress, when measured by its intensity and duration, is so severe that no reasonable man could be expected to endure it.” Benton, 2020 IL App (1st) 190549, ¶ 64 (quoting Restatement (Second) of Torts § 46, comments d, j (1965)). ¶ 24 After reviewing the record, we find that the trial court’s judgment finding pl 2024Rather, as explained in Benton: “[L]iability only attaches ‘where the conduct has been so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community’ and where the distress, when measured by its intensity and duration, is so severe that no reasonable man could be expected to endure it.” Benton, 2020 IL App (1st) 190549, ¶ 64 (quoting Restatement (Second) of Torts § 46, comments d, j (1965)). ¶ 24 After reviewing the record, we find that the trial court’s judgment finding pl | 1 | 1 |
Schweihs v. Chase Home Finance, LLCgreen2 sentences2024An IIED claim requires proof that “the defendant’s conduct was extreme and outrageous, (2) the defendant intended his conduct to cause severe emotional distress or knew that there was a high probability that his conduct would cause severe emotional distress, and (3) the defendant’s conduct did, in fact, cause severe emotional distress to the plaintiff.” DiPietra v. GATX Corp., 2020 IL App (1st) 192196 , ¶ 50. ¶ 112 Conduct is considered “extreme and outrageous” only where it is “so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be rega 2024An IIED claim requires proof that “the defendant’s conduct was extreme and outrageous, (2) the defendant intended his conduct to cause severe emotional distress or knew that there was a high probability that his conduct would cause severe emotional distress, and (3) the defendant’s conduct did, in fact, cause severe emotional distress to the plaintiff.” DiPietra v. GATX Corp., 2020 IL App (1st) 192196 , ¶ 50. ¶ 112 Conduct is considered “extreme and outrageous” only where it is “so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be rega | 1 | 1 |
Farrar v. Bracamondesgreen2 sentences2024See Farrar v. Bracamondes, 332 F. Supp. 2d 1126, 1131 (N.D. 2024See Farrar v. Bracamondes, 332 F. Supp. 2d 1126, 1131 (N.D. | 1 | 1 |
In Re Alfred HHgreen1 sentence2021See In re Alfred H.H., 233 Ill. 2d 345, 351 (2009) (“As a general rule, courts in Illinois do not decide moot questions, render advisory opinions, or consider issues where the result will not be affected regardless of how those issues are decided.”). ¶ 47 Because the defamation and false light claims are timely, Ekl’s arguments that Ciolino’s civil conspiracy claim and IIED claim are time-barred because they are derivative and thus subject to the same one-year statute of limitations fail. ¶ 48 Finally, Ekl asserts that reversal of the appellate court’s decision is warranted for the additional | 1 | 1 |
Lochner v. New Yorkred1 sentence2020App. 3d at 957 (quoting Lochner v. New York, 198 U.S. 45, 75 (1905)). ¶ 45 Stripped of all allegations of conduct before November 6, 2013 concerning released claims, and accepting all well-pleaded facts as true, the count I IIED claim of the amended complaint essentially alleged that for approximately four years defendant intentionally and knowingly made false statements about plaintiff engaging in fraudulent and criminal activity by (1) making false - 17 - No. 1-19-1819 complaints with federal agencies in 2014 that falsely accused plaintiff of misusing federal funds despite defendant’s knowle | 1 | 1 |
Class v. New Jersey Life Insurancegreen2 sentences2020Class v. New Jersey Life Insurance Co., 746 F. Supp. 776, 779 (N.D. 2020Class v. New Jersey Life Insurance Co., 746 F. Supp. 776, 779 (N.D. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Sandholm v. Kuecker
green
2 sentences2020Sandholm, 2012 IL 111443, ¶ 45 . ¶ 33 Addressing plaintiff’s IIED claim first, we determine whether defendant’s complained-of actions after the November 6, 2013 release were protected under the Act by considering whether his actions were in furtherance of his constitutional rights of petition, speech, association, or participation in government to obtain favorable government action. 2020Sandholm, 2012 IL 111443, ¶ 45 ; Garrido, 2013 IL App (1st) 120466, ¶ 23 . ¶ 38 Defendant argues that plaintiff’s IIED claim was meritless because his actions could never rise to the level of extreme and outrageous conduct as a matter of law since much of defendant’s - 14 - No. 1-19-1819 alleged misconduct was barred by the 2013 settlement agreement. | 3 | 2020–2020 |
Stein v. Krislov
green
2 sentences2020Stein, 2013 IL App (1st) 113806, ¶ 16 . ¶ 38 Under the second prong of the analysis, defendant has the burden to show that plaintiff’s IIED claim was solely based on, related to, or in response to defendant’s acts in furtherance of his right to petition the government. 2020Stein, 2013 IL App (1st) 113806, ¶ 16 . ¶ 35 Under the second prong of the analysis, defendant has the burden to show that plaintiff’s IIED claim was solely based on, related to, or in response to defendant’s acts in furtherance of his right to petition the government. | 3 | 2020–2020 |
Garrido v. Arena
green
2 sentences2020Sandholm, 2012 IL 111443, ¶ 45 ; Garrido, 2013 IL App (1st) 120466, ¶ 23 . ¶ 41 Defendant argues that plaintiff’s IIED claim was meritless because his actions could never rise to the level of extreme and outrageous conduct as a matter of law since much of defendant’s - 15 - No. 1-19-1819 alleged misconduct was barred by the 2013 settlement agreement. 2020Sandholm, 2012 IL 111443, ¶ 45 ; Garrido, 2013 IL App (1st) 120466, ¶ 23 . ¶ 38 Defendant argues that plaintiff’s IIED claim was meritless because his actions could never rise to the level of extreme and outrageous conduct as a matter of law since much of defendant’s - 14 - No. 1-19-1819 alleged misconduct was barred by the 2013 settlement agreement. | 3 | 2020–2020 |
McGrath v. Fahey
green
2 sentences2024Specifically, defendant did not satisfy the first and third elements, i.e., the evidence did not show that plaintiff’s conduct was “truly extreme and outrageous” or caused severe emotional distress. ¶ 25 Regarding the first element of an IIED claim, “[t]he outrageousness of a [person]’s conduct must be determined in view of all the facts and circumstances pleaded and proved in a particular case.” McGrath, 126 Ill. 2d at 86 . 2024Specifically, defendant did not satisfy the first and third elements, i.e., the evidence did not show that plaintiff’s conduct was “truly extreme and outrageous” or caused severe emotional distress. ¶ 25 Regarding the first element of an IIED claim, “[t]he outrageousness of a [person]’s conduct must be determined in view of all the facts and circumstances pleaded and proved in a particular case.” McGrath, 126 Ill. 2d at 86 . | 2 | 2020–2024 |
Wade v. Stewart Title Guaranty Company
green
2 sentences2024Id. (citing Wade, 2017 IL App (1st) 161765, ¶ 59 ). ¶ 22 Our supreme court has set forth the elements of an IIED claim as follows: “First, the conduct involved must be truly extreme and outrageous. 2024Id. (citing Wade, 2017 IL App (1st) 161765, ¶ 59 ). ¶ 22 Our supreme court has set forth the elements of an IIED claim as follows: “First, the conduct involved must be truly extreme and outrageous. | 1 | 2024–2024 |
Bedin v. Northwestern Memorial Hospital
green
1 sentence2021For the reasons explained above, we affirm the circuit court’s judgment. 19 No. 1-19-0723 ¶ 51 Affirmed. 20 No. 1-19-0723 No. 1-19-0723 Cite as: Bedin v. Northwestern Memorial Hospital, 2021 IL App (1st) 190723 Decision Under Review: Appeal from the Circuit Court of Cook County, No. 18-L-3315; the Hon. | 1 | 2021–2021 |
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.