vague allegation error in Illinois

2026Oct. 1, 2020), any argument appearing in an appellant’s brief must “contain the contentions of the appellant and the reasons therefor, with citation of the authorities and the pages of the record relied on.” “An issue that is merely listed or included in a vague allegation of error is not ‘argued’ and will not satisfy the requirements of the rule. [Citations.] Moreover, an argument that is developed beyond mere list or vague allegation may be insufficient if it does not include citations to authority.” Vancura v. Katris, 238 Ill. 2d 352, 369-70 (2010). ¶ 44 Here, William argues that an applica

2026See Vancura v. Katris, 238 Ill. 2d 352, 370 (2010) (“An issue that is merely listed or included in a vague allegation of error is not “argued” and will not satisfy the requirements of [Rule 341].”). ¶ 22 Next, rule 341(h)(6) requires a “Statement of Facts, which shall contain the facts necessary to an understanding of the case, stated accurately and fairly without argument or comment, and 5 No. 1-24-2318 with appropriate reference to the pages of the record on appeal.” Ill.

2025See Hayashi v. Illinois Department of Financial and Professional Regulation, 2014 IL 116023, ¶ 50 ; Bartlow, 2014 IL 115152 , ¶ 52 (an issue that is merely listed or included in a vague allegation of error is not “argued” and does not satisfy Illinois Supreme Court Rule 341(h) (eff.

2015Feb. 6, 2013) (argument in an appellant’s brief “shall contain the contentions of the appellant and the reasons therefor, with citation of the authorities and the pages of the record relied on. *** Points not argued are waived and shall not be raised in the reply brief, in oral argument, or on petition for rehearing”); Bartlow v. Costigan, 2014 IL 115152, ¶ 52 (holding that arguments raised in a cursory fashion which are not fully briefed and argued are forfeited by the parties); Vancura v. Katris, 238 Ill. 2d 352, 370 (2010) (noting that an issue “merely listed or included in a vague allegati

2021See Vancura v. Katris, 238 Ill. 2d 352, 370 , 939 N.E.2d 328, 340 (2010) (“An issue that is merely listed or included in a vague allegation of error is not ‘argued’ and will not satisfy the requirements of the rule.”); see also People v. Phillips, 215 Ill. 2d 554, 565 , 831 N.E.2d 574, 581 (2005) (finding an argument forfeited due to appellant’s failure to support his assertion with argument or cite relevant authority).

2021See Vancura v. Katris, 238 Ill. 2d 352, 370 , 939 N.E.2d 328, 340 (2010) (“An issue that is merely listed or included in a vague allegation of error is not ‘argued’ and will not satisfy the requirements of the rule.”); see also People v. Phillips, 215 Ill. 2d 554, 565 , 831 N.E.2d 574, 581 (2005) (finding an argument forfeited due to appellant’s failure to support his assertion with argument or cite relevant authority).

2014As our appellate court has repeatedly recognized, a reviewing court is “entitled to have issues clearly defined with pertinent authority cited and cohesive arguments presented.” (Internal quotation marks omitted.) Velocity Investments, LLC v. Alston, 397 Ill.

2014As our appellate court has repeatedly recognized, a reviewing court is “entitled to have issues clearly defined with pertinent authority cited and cohesive arguments presented.” (Internal quotation marks omitted.) Velocity Investments, LLC v. Alston, 397 Ill.

2010See, e.g., People v. Phillips, 215 Ill. 2d 554, 565 (2005) (issue forfeited where defendant raised it but failed to make any argument or citation to relevant authority); People v. Franklin, 167 Ill. 2d 1, 20 (1995) (issues forfeited where defendant provided no argument to support claims of error); People v. Guest, 166 Ill. 2d 381, 413-14 (1995) (one sentence in brief indicating that defendant “incorporated” all claims made in earlier proceedings not sufficient to satisfy Rule 341, resulting in forfeiture of claims).

2010See, e.g., People v. Phillips, 215 Ill. 2d 554, 565 (2005) (issue forfeited where defendant raised it but failed to make any argument or citation to relevant authority); People v. Franklin, 167 Ill. 2d 1, 20 (1995) (issues forfeited where defendant provided no argument to support claims of error); People v. Guest, 166 Ill. 2d 381, 413-14 (1995) (one sentence in brief indicating that defendant “incorporated” all claims made in earlier proceedings not sufficient to satisfy Rule 341, resulting in forfeiture of claims).

2010See, e.g., People v. Phillips, 215 Ill. 2d 554, 565 (2005) (issue forfeited where defendant raised it but failed to make any argument or citation to relevant authority); People v. Franklin, 167 Ill. 2d 1, 20 (1995) (issues forfeited where defendant provided no argument to support claims of error); People v. Guest, 166 Ill. 2d 381, 413-14 (1995) (one sentence in brief indicating that defendant “incorporated” all claims made in earlier proceedings not sufficient to satisfy Rule 341, resulting in forfeiture of claims).

2010See, e.g., People v. Phillips, 215 Ill. 2d 554, 565 (2005) (issue forfeited where defendant raised it but failed to make any argument or citation to relevant authority); People v. Franklin, 167 Ill. 2d 1, 20 (1995) (issues forfeited where defendant provided no argument to support claims of error); People v. Guest, 166 Ill. 2d 381, 413-14 (1995) (one sentence in brief indicating that defendant “incorporated” all claims made in earlier proceedings not sufficient to satisfy Rule 341, resulting in forfeiture of claims).

2026Further, “[a]n issue that is merely listed in a vague allegation of error is not argued, fails to satisfy Rule 341(h)(7), and is, therefore, forfeited.” Atlas v. Mayer Hoffman McCann, P.C., 2019 IL App (1st) 180939, ¶ 36 (citing Vancura v. Katris, 238 Ill. 2d 352, 370 (2010)). ¶ 13 Supreme court rules are “not mere suggestions.” SMS Financial CH, LLC v. Feurer, 2025 IL App (1st) 250033, ¶ 40 .

2023Atlas v. Mayer Hoffman McCann, P.C., 2019 IL App (1st) 180939, ¶ 33 ; see also Vancura v. Katris, 238 Ill. 2d 352, 370 (2010) (“An issue that is merely listed or included in a vague allegation of error is not ‘argued’ and will not satisfy the requirements of the rule.”).

2024Oct. 1, 2020). “ ‘An issue that is merely listed or included in a vague allegation of error is not “argued” and will not satisfy the requirements of the rule.’ ” People v. Nere, 2018 IL 122566 , ¶ 25 (quoting Vancura v. Katris, 238 Ill. 2d 352, 370 (2010)). 17 ¶ 47 III.

2022Oct. 1, 2020). “ ‘An issue that is merely listed or included in a vague allegation of error is not “argued” and will not satisfy the requirements of the rule.’ ” People v. Nere, 2018 IL 122566, ¶ 25 (quoting Vancura v. Katris, 238 Ill. 2d 352, 370 (2010)). ¶ 14 Respondent argues that the trial court misapprehended the facts regarding her drug use and asks us to find the court’s dispositional order against the manifest weight of the evidence.

2026See, e.g., McCann v. Dart, 2015 IL App (1st) 141291, ¶ 18 . ¶ 70 Second, where the circuit court sustains the State’s objection and excludes defense evidence, the defendant preserves the issue by making a sufficiently specific offer of proof demonstrating the substance of the proposed testimony and the basis for its admissibility.

2025Oct. 1, 2020)].’ ” (quoting Vancura v. Katris, 238 Ill. 2d 352, 369-70 (2010))); In re Alexander R., 377 Ill.

2025See Hayashi v. Illinois Department of Financial and Professional Regulation, 2014 IL 116023, ¶ 50 ; Bartlow, 2014 IL 115152 , ¶ 52 (an issue that is merely listed or included in a vague allegation of error is not “argued” and does not satisfy Illinois Supreme Court Rule 341(h) (eff.

2023Oct. 1, 2020), the appellant must present to this court an argument “which shall contain the contentions of the appellant and the reasons therefor, with citation of the authorities and the pages of the record relied on.” Rule 341(h)(7) requires “[b]oth argument and citation to relevant authority,” and “[a]n issue that is merely listed or included in a vague allegation of error is not ‘argued’ and will not satisfy the requirements of the rule.” Vancura v. Katris, 238 Ill. 2d 352, 370 (2010); Hall v. Naper Gold Hospitality, LLC, 2012 IL App (2d) 111151, ¶ 12 (mere contention, without argument, d

2022An issue that is merely listed or included in a vague allegation of error is not ‘argued’ and will not satisfy the requirements of the rule”); Kic v. Bianucci, 2011 IL App (1st) 100622, ¶ 23 (“A failure to cite relevant authority violates Rule 341 and can cause a party to forfeit consideration of the issue”); Sakellariadis v. Campbell, 391 Ill.

2022An issue that is merely listed or included in a vague allegation of error is not ‘argued’ and will not satisfy the requirements of the rule”); Kic v. Bianucci, 2011 IL App (1st) 100622, ¶ 23 (“A failure to cite relevant authority violates Rule 341 and can cause a party to forfeit consideration of the issue”); Sakellariadis v. Campbell, 391 Ill.

2022App. 3d 795, 804 (2009) (“The failure to assert a well-reasoned argument supported by legal authority is a violation of Supreme Court Rule 341(h)(7) [citation], - 37 - 2022 IL App (2d) 191099-U resulting in waiver”); People v. Patel, 366 Ill.

2020See Venturella, 2017 IL App (1st) 160565, ¶ 23 .

2020First National Bank of LaGrange v. -3- No. 1-19-2459 Lowrey, 375 Ill.

2019“It is well settled that a void judgment may be set aside at any time. [Citations.] Laches do not apply in setting aside a void judgment for if the judgment is void, it is without any legal effect. [Citations.]” Johnson v. Hawkins, 4 Ill.