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

56 Illinois opinions name it 2 courts 1975–2026 3 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 (20)

CaseFollowedCited
Frank's Maintenance & Engineering, Inc. v. C. A. Rorerts Co.green
illappct · 1980 · cited in 3 Illinois opinions naming this issue, 2006–2006
2 sentences

2006Roberts Co., 86 Ill.App.3d 980, 989 , 42 Ill.Dec. 25 , 408 N.E.2d 403 (1980).

2006Roberts Co., 86 Ill.

33
Liccardi v. Stolt Terminals, Inc.green
ill · 1997 · cited in 3 Illinois opinions naming this issue, 2005–2009
2 sentences

2009App. 3d 141, 150 , 669 N.E.2d 1192, 1199 (1996) (the contract called for recovery based on the relative culpability of the parties), aff’d on other grounds, 178 Ill. 2d 540 , 687 N.E.2d 968 (1997); see also Hahn v. Norfolk & Western Ry.

2009App. 3d 141, 150 , 669 N.E.2d 1192, 1199 (1996) (the contract called for recovery based on the relative culpability of the parties), aff’d on other grounds, 178 Ill. 2d 540 , 687 N.E.2d 968 (1997); see also Hahn v. Norfolk & Western Ry.

23
Trans States Airlines v. Pratt & Whitney Canada, Inc.green
ill · 1997 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006In contrast to a contractual claim, which alleges only economic damages or disappointed commercial expectations, a tort claim alleges the infliction of personal injury or property damage by a sudden or dangerous occurrence (Moorman, 91 Ill. 2d at 86 , 435 N.E.2d at 450 ) — “property damage” meaning damage to property other than the defective product itself (Trans States Airlines v. Pratt & Whitney Canada, Inc., 177 Ill. 2d 21, 42 , 682 N.E.2d 45, 54-55 (1997)).

2006In contrast to a contractual claim, which alleges only economic damages or disappointed commercial expectations, a tort claim alleges the infliction of personal injury or property damage by a sudden or dangerous occurrence (Moorman, 91 Ill. 2d at 86 , 435 N.E.2d at 450 ) — “property damage” meaning damage to property other than the defective product itself (Trans States Airlines v. Pratt & Whitney Canada, Inc., 177 Ill. 2d 21, 42 , 682 N.E.2d 45, 54-55 (1997)).

22
Zimmerman v. Northfield Real Estate, Inc.green
illappct · 1987 · cited in 2 Illinois opinions naming this issue, 2005–2005
2 sentences

2005See Zimmerman v. Northfield Real Estate, Inc., 156 Ill.

2005See Zimmerman v. Northfield Real Estate, Inc., 156 Ill.App.3d 154 , 109 Ill.Dec. 541 , 510 N.E.2d 409 (1986).

22
Prudential Insurance Co. v. Van Matregreen
illappct · 1987 · cited in 2 Illinois opinions naming this issue, 2004–2004
2 sentences

2004See Prudential Insurance Co. of America v. Van Matre , 158 Ill.

2004See Prudential Insurance Co. of America v. Van Matre, 158 Ill.

22
State of Illinois Department of Central Management Services v. State of Illinois Labor Relations Boardgreen
illappct · 2007 · cited in 2 Illinois opinions naming this issue, 2018–2020
2 sentences

2020The Board rejected City Colleges waiver argument finding that the Union did not clearly and unmistakably waive its right to arbitration. ¶ 44 “The contractual waiver of a statutory right in a labor agreement must be ‘clear and unmistakable.’ ” State of Illinois Department of Central Management Services v. State of Illinois Labor Relations Board, State Panel, 373 Ill.

2018App. 3d 242 , 255, 311 Ill.Dec. 600 , 869 N.E.2d 274 (2007) (stating that a labor agreement can contain a contractual waiver of a statutory right if the waiver is unmistakable and clear).

12
Afscme v. Islrbgreen
illappct · 1989 · cited in 2 Illinois opinions naming this issue, 1990–1991
2 sentences

1991See AFSCME, 190 Ill.

1990App. 3d 259 , 546 N.E.2d 687 (interpreting the effect of a zipper clause under the Illinois Public Labor Relations Act).) Thus, for a contractual waiver to be found, the language of the agreement in light of any evidence presented on bargaining history must present “a clear and unmistakable” agreement to waive midterm bargaining.

12
Buchalo v. Country Mutual Insurancegreen
illappct · 1980 · cited in 1 Illinois opinions naming this issue, 2019–2019
1 sentence

2019See Buchalo v. Country Mutual Insurance Co., 83 Ill.

11
City of Evanston v. Create, Inc.green
ill · 1981 · cited in 1 Illinois opinions naming this issue, 2018–2018
1 sentence

2018City of Evanston v. Create, Inc., 85 Ill. 2d 101, 114 (1981).

11
cluster 770917green
ca7 · 2000 · cited in 1 Illinois opinions naming this issue, 2016–2016
1 sentence

2016But the exculpatory clauses (setting aside the question of whether they are effectual in these circumstances) pertain to liability, not jurisdiction. “[J]urisdiction and liability are two separate inquiries.” Central States, Southeast & Southwest Areas Pension Fund v. Reimer Express World Corp., 230 F.3d 934, 944 (7th Cir. 2000); see also Gramercy Advisors LLC v. Lowery, No. 01-14-00904-CV, 2015 WL 3981610 , at *12 (Tex. Ct. App. June 30, 2015) (by invoking a contractual clause in which the plaintiffs disclaimed reliance on Gramercy’s tax advice, the Gramercy defendants “conflate liability wit

11
Colonial Penn Insurance v. Guzorekgreen
ind · 1997 · cited in 1 Illinois opinions naming this issue, 2015–2015
1 sentence

2015See Colonial Penn Insurance Co. v. Guzorek, 690 N.E.2d 664, 669 (Ind. 1997) (holding, “in the case of an unambiguous policy requiring notice to trigger ‘automatic’ coverage of additional cars, that provision is enforceable and can be invoked to deny coverage if notice is not given”); Auto-Owners Insurance Co. v. Winter, 469 N.W.2d 314, 315 (Mich. Ct. App. 1991) (adhering to the plain reading of an insurance policy with a clear notice requirement for coverage on a newly acquired vehicle).

11
Auto-Owners Insurance v. Wintergreen
michctapp · 1991 · cited in 1 Illinois opinions naming this issue, 2015–2015
1 sentence

2015See Colonial Penn Insurance Co. v. Guzorek, 690 N.E.2d 664, 669 (Ind. 1997) (holding, “in the case of an unambiguous policy requiring notice to trigger ‘automatic’ coverage of additional cars, that provision is enforceable and can be invoked to deny coverage if notice is not given”); Auto-Owners Insurance Co. v. Winter, 469 N.W.2d 314, 315 (Mich. Ct. App. 1991) (adhering to the plain reading of an insurance policy with a clear notice requirement for coverage on a newly acquired vehicle).

11
Liccardi v. Stolt Terminals (Chicago), Inc.green
illappct · 1996 · cited in 1 Illinois opinions naming this issue, 2009–2009
2 sentences

2009App. 3d 1002, 1006 , 830 N.E.2d 636, 641-42 (2005) (citing Herington and Liccardi for purposes of a contractual waiver of the Kotecki damage cap {Kotecki v. Cyclops Welding Corp., 146 Ill. 2d 155 , 585 N.E.2d 1023 (1991))); Liccardi v. Stolt Terminals (Chicago), Inc., 283 Ill.

2009App. 3d 141, 150 , 669 N.E.2d 1192, 1199 (1996) (the contract called for recovery based on the relative culpability of the parties), aff’d on other grounds, 178 Ill. 2d 540 , 687 N.E.2d 968 (1997); see also Hahn v. Norfolk & Western Ry.

11
Estate of Willis v. Kiferbaum Construction Corp.green
illappct · 2005 · cited in 1 Illinois opinions naming this issue, 2009–2009
1 sentence

2009App. 3d 1002, 1006 , 830 N.E.2d 636, 641-42 (2005) (citing Herington and Liccardi for purposes of a contractual waiver of the Kotecki damage cap {Kotecki v. Cyclops Welding Corp., 146 Ill. 2d 155 , 585 N.E.2d 1023 (1991))); Liccardi v. Stolt Terminals (Chicago), Inc., 283 Ill.

11
Haight v. Aldridge Elec. Co., Inc.green
illappct · 1991 · cited in 1 Illinois opinions naming this issue, 1998–1998
11
Local Union 1395, International Brotherhood Of Electrical Workers, Afl-Cio, Petitioner v. National Labor Relations Boardgreen
cadc · 1986 · cited in 1 Illinois opinions naming this issue, 1988–1988
11
Beth Israel Hospital v. National Labor Relations Boardgreen
scotus · 1978 · cited in 1 Illinois opinions naming this issue, 1988–1988
11
Fry v. George Elkins Co.green
calctapp · 1958 · cited in 1 Illinois opinions naming this issue, 1981–1981
11
Travelers Insurance Company v. PINKERTON-HAYS LUMBER COMPANYgreen
fladistctapp · 1960 · cited in 1 Illinois opinions naming this issue, 1979–1979
11
Liberty National Bank of Chicago v. Newberrygreen
illappct · 1955 · cited in 1 Illinois opinions naming this issue, 1975–1975
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 (40)

CaseCitedYears
In Re Estate of Marcucci green
ill · 1973
2 sentences

1991Any attempt to prove the existence of a contract not to revoke at such proceedings is irrelevant since it is tantamount to an attempt to prove a contractual claim against the estate before the appointment of an indispensable party, the executor.” 54 Ill. 2d at 270 , 296 N.E.2d at 851 .

1991Any attempt to prove the existence of a contract not to revoke at such proceedings is irrelevant since it is tantamount to an attempt to prove a contractual claim against the estate before the appointment of an indispensable party, the executor.” 54 Ill. 2d at 270 , 296 N.E.2d at 851 .

41975–1991
American Federation of State, County & Municipal Employees v. Illinois State Labor Relations Board green
illappct · 1995
2 sentences

2007The contractual waiver of a statutory right in a labor agreement must be “clear and unmistakable.” American, 274 Ill.

2007The contractual waiver of a statu- tory right in a labor agreement must be "clear and unmistakable." American, 274 Ill.

32007–2020
Anderson Electric, Inc. v. Ledbetter Erection Corp. green
ill · 1986
2 sentences

1991The court has stated: “A plaintiff seeking to recover purely economic losses due to defeated expectations of a commercial bargain cannot recover in tort, regardless of the plaintiff’s inability to recover under an action in contract.” (Emphasis added.) (Anderson Electric, Inc. v. Ledbetter Erection Corp. (1986), 115 Ill. 2d 146, 153 .) Thus, while Moorman may apply where the plaintiff has no direct contractual relationship with the defendant (Anderson, 115 Ill. 2d at 148 ) or where the plaintiff’s contractual claim is barred by the statute of limitations (Moorman, 91 Ill. 2d at 92-94 ), the su

1991The court has stated: “A plaintiff seeking to recover purely economic losses due to defeated expectations of a commercial bargain cannot recover in tort, regardless of the plaintiff’s inability to recover under an action in contract.” (Emphasis added.) (Anderson Electric, Inc. v. Ledbetter Erection Corp. (1986), 115 Ill. 2d 146, 153 .) Thus, while Moorman may apply where the plaintiff has no direct contractual relationship with the defendant (Anderson, 115 Ill. 2d at 148 ) or where the plaintiff’s contractual claim is barred by the statute of limitations (Moorman, 91 Ill. 2d at 92-94 ), the su

31991–2006
Moorman Manufacturing Co. v. National Tank Co. green
ill · 1982
2 sentences

2006In contrast to a contractual claim, which alleges only economic damages or disappointed commercial expectations, a tort claim alleges the infliction of personal injury or property damage by a sudden or dangerous occurrence (Moorman, 91 Ill. 2d at 86 , 435 N.E.2d at 450 ) — “property damage” meaning damage to property other than the defective product itself (Trans States Airlines v. Pratt & Whitney Canada, Inc., 177 Ill. 2d 21, 42 , 682 N.E.2d 45, 54-55 (1997)).

2006In contrast to a contractual claim, which alleges only economic damages or disappointed commercial expectations, a tort claim alleges the infliction of personal injury or property damage by a sudden or dangerous occurrence (Moorman, 91 Ill. 2d at 86 , 435 N.E.2d at 450 ) — “property damage” meaning damage to property other than the defective product itself (Trans States Airlines v. Pratt & Whitney Canada, Inc., 177 Ill. 2d 21, 42 , 682 N.E.2d 45, 54-55 (1997)).

31991–2006
Stark Excavating v. Carter Construction Services green
illappct · 2012
2 sentences

2017As a discussion of two cases demonstrates, the answer is that a claim for quantum meruit lies when the work that the plaintiff performed was wholly beyond the subject matter of the contract that existed between the parties. ¶ 40 The first case is the one on which Archon principally relies, Stark, 2012 IL App (4th) 110357 .

2017As a discussion of two cases demonstrates, the answer is that a claim for quantum meruit lies when the work that the plaintiff performed was wholly beyond the subject matter of the contract that existed between the parties. ¶ 40 The first case is the one on which Archon principally relies, Stark, 2012 IL App (4th) 110357 .

22017–2017
Leonard v. Autocar Sales & Service Co. green
ill · 1945
2 sentences

2011And that impossibility was as a result of the conduct of the defendants." (Emphasis added.) ¶ 39 Impossibility of performance is a contractual doctrine excusing performance "where performance is rendered objectively impossible due to destruction of the subject matter of the contract or by operation of law." YPI 180 N. LaSalle Owner, LLC v. 180 N. LaSalle II, LLC, 403 Ill.App.3d 1, 6 , 342 Ill.Dec. 879 , 933 N.E.2d 860 (2010) (citing Leonard v. Autocar Sales & Service Co., 392 Ill. 182, 187 , 64 N.E.2d 477 (1945)).

2011And that impossibility was as a result of the conduct of the defendants." (Emphasis added.) ¶ 39 Impossibility of performance is a contractual doctrine excusing performance "where performance is rendered objectively impossible due to destruction of the subject matter of the contract or by operation of law." YPI 180 N. LaSalle Owner, LLC v. 180 N. LaSalle II, LLC, 403 Ill.App.3d 1, 6 , 342 Ill.Dec. 879 , 933 N.E.2d 860 (2010) (citing Leonard v. Autocar Sales & Service Co., 392 Ill. 182, 187 , 64 N.E.2d 477 (1945)).

22011–2011
YPI 180 N. LaSalle Owner, LLC v. 180 N. LaSalle II, LLC green
illappct · 2010
2 sentences

2011And that impossibility was as a result of the conduct of the defendants." (Emphasis added.) ¶ 39 Impossibility of performance is a contractual doctrine excusing performance "where performance is rendered objectively impossible due to destruction of the subject matter of the contract or by operation of law." YPI 180 N. LaSalle Owner, LLC v. 180 N. LaSalle II, LLC, 403 Ill.App.3d 1, 6 , 342 Ill.Dec. 879 , 933 N.E.2d 860 (2010) (citing Leonard v. Autocar Sales & Service Co., 392 Ill. 182, 187 , 64 N.E.2d 477 (1945)).

2011And that impossibility was as a result of the conduct of the defendants." (Emphasis added.) ¶ 39 Impossibility of performance is a contractual doctrine excusing performance "where performance is rendered objectively impossible due to destruction of the subject matter of the contract or by operation of law." YPI 180 N. LaSalle Owner, LLC v. 180 N. LaSalle II, LLC, 403 Ill.App.3d 1, 6 , 342 Ill.Dec. 879 , 933 N.E.2d 860 (2010) (citing Leonard v. Autocar Sales & Service Co., 392 Ill. 182, 187 , 64 N.E.2d 477 (1945)).

22011–2011
Williams v. Illinois State Scholarship Commission green
ill · 1990
2 sentences

2007Moreover, with the contractual clause being embedded in a boilerplate agreement, its significance was “greatly reduced because of the inequality in the parties’ bargaining power.” Williams, 139 Ill. 2d at 72 .

2007Moreover, with the contractual clause being embedded in a boilerplate agreement, its significance was “greatly reduced because of the inequality in the parties’ bargaining power.” Williams, 139 Ill. 2d at 72 .

22007–2007
StarNet Insurance Company v. Adam Ruprecht green
ca7 · 2021
1 sentence

2026Id. at 347-48 . ¶ 46 Here, there is neither a contract nor privity between ACA and Builder.

12026–2026
People v. Brown green
ill · 2020
1 sentence

2024“Waiver is an intentional relinquishment or abandonment of a known right or privilege.” People v. Brown, 2020 IL 125203, ¶ 25 .

12024–2024
Berger v. Matthews green
illappct · 1991
1 sentence

2024Conversely, fees such as those at issue in Barrington Bank’s motion to tax costs are awarded to prevailing parties (see 735 ILCS 5/5-108, 5- 109 (West 2022)), so these claims could not have arisen until after the trial court entered its judgment in the case. ¶ 24 Further guidance can be found in Berger v. Matthews, 216 Ill.

12024–2024
BMO Harris Bank N.A. v. Joe Contarino, Inc. green
illappct · 2017
1 sentence

2017Specifically, it argued that: (1) as to Rockford, the court was mistaken as to the timing of the receipt of funds, as BMO was the only party with a lien on the funds currently held by Briargate; (2) as to Rockford, the court misstated the law in holding that a forbearance agreement (which, BMO claimed, gives rise only to a contractual claim, not a lien, on collected rents) takes priority over a lien right; and (3) as to Rockford, even if Rockford’s -6­ 2017 IL App (2d) 160371 claim was superior to BMO’s claim, the forbearance obligations were never proved up and JCI might not owe Rockford any

12017–2017
Harrington v. State of New York Office of Court Administration neutral
ny · 1984
1 sentence

2011App. 3d 1, 6 , 933 N.E.2d 860 (2010) (citing Leonard v. Autocar Sales & Service Co., 392 Ill. 182, 187 , 464 N.E.2d 477 (1945)).

12011–2011
Loman v. Freeman green
illappct · 2006
2 sentences

2010In Loman v. Freeman, 375 Ill.App.3d 445, 456 , 314 Ill.Dec. 446 , 874 N.E.2d 542 (2006), the court explained, "In contrast to a contractual claim, which alleges only economic damages or disappointed commercial expectations, a tort claim alleges the infliction of personal injury or property damage by a sudden or dangerous occurrence." "Property damage" refers to damage to property other than the defective product itself.

2010In Loman v. Freeman, 375 Ill.App.3d 445, 456 , 314 Ill.Dec. 446 , 874 N.E.2d 542 (2006), the court explained, "In contrast to a contractual claim, which alleges only economic damages or disappointed commercial expectations, a tort claim alleges the infliction of personal injury or property damage by a sudden or dangerous occurrence." "Property damage" refers to damage to property other than the defective product itself.

12010–2010
Kotecki v. Cyclops Welding Corp. green
ill · 1992
2 sentences

2009App. 3d 1002, 1006 , 830 N.E.2d 636, 641-42 (2005) (citing Herington and Liccardi for purposes of a contractual waiver of the Kotecki damage cap {Kotecki v. Cyclops Welding Corp., 146 Ill. 2d 155 , 585 N.E.2d 1023 (1991))); Liccardi v. Stolt Terminals (Chicago), Inc., 283 Ill.

2009App. 3d 1002, 1006 , 830 N.E.2d 636, 641-42 (2005) (citing Herington and Liccardi for purposes of a contractual waiver of the Kotecki damage cap {Kotecki v. Cyclops Welding Corp., 146 Ill. 2d 155 , 585 N.E.2d 1023 (1991))); Liccardi v. Stolt Terminals (Chicago), Inc., 283 Ill.

12009–2009
Smith v. Bogard green
illappct · 2007
2 sentences

2009This exact issue was raised and decided against the contractor in Smith v. Bogard, 377 Ill.

2009This exact issue was raised and decided against the contractor in Smith v. Bogard, 377 Ill.App.3d 842 , 316 Ill.Dec. 476 , 879 N.E.2d 543 (2007).

12009–2009
Allstate Insurance v. Smiley green
illappct · 1995
11999–1999
Shaw v. Bridges-Gallagher, Inc. green
illappct · 1988
11993–1993
LeFevour v. Howorka green
illappct · 1991
11993–1993
Lingle v. Norge Division of Magic Chef, Inc. green
scotus · 1988
11993–1993
Board of Education v. Illinois Educational Labor Relations Board green
illappct · 1990
11991–1991
Star Finance Corp. v. McGee green
illappct · 1975
11990–1990
Calanca v. D & S MANUFACTURING CO. green
illappct · 1987
11990–1990
Martin-Trigona v. Roderick green
illappct · 1975
11990–1990
State v. Maine State Employees Ass'n green
me · 1984
11988–1988
State v. Maine State Employees Ass'n green
me · 1985
11988–1988
Alexander v. Gardner-Denver Co. green
scotus · 1974
11988–1988
Green v. Hughes Aircraft Co. green
casd · 1985
11988–1988
Rittenhouse & Embree Co. v. Warren Construction Co. green
ill · 1914
11987–1987
Kuhlmann v. Board of Trustees of the Police Pension Fund green
illappct · 1982
11985–1985
Huckleberry v. Wilson green
· 1955
11981–1981
Jack Spring, Inc. v. Little green
ill · 1972
11980–1980
In Re Estate of Holmberg green
ill · 1948
11979–1979
Nikkari v. Jackson green
minn · 1948
11979–1979
Ohio Cas. Ins. Co. v. Gantt green
· 1951
11979–1979
Conley v. Singleton neutral
fladistctapp · 1965
11979–1979
Williams v. Moran neutral
miss · 1970
11979–1979
Van Houten v. Trust Co. of Chicago neutral
ill · 1952
11975–1975
International Shoe Co. v. Washington green
scotus · 1945
11975–1975
Kolivera v. Hartford Fire Insurance green
illappct · 1972
11975–1975

Statutes the citing opinions construe

IL § 735 ILCS 5/2-615 (4) IL § 735 ILCS 5/2-619 (4) IL § 740 ILCS 35/1 (3) IL § 815 ILCS 505/2 (3) USC § 29u.s.c.185 (3)

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

TX 265 (1949–2026) MI 156 (1969–2026) CA 139 (1958–2026) NY 105 (1899–2026) NJ 61 (1958–2026) IL 56 (1975–2026) DE 47 (1982–2026) GA 38 (1958–2024) PA 37 (1957–2026) FL 37 (1967–2026) OH 33 (1994–2026) MA 30 (1976–2026) AL 30 (1920–2023) LA 26 (1913–2019) MD 24 (1979–2023) WA 21 (1991–2025) MO 20 (1934–2025) NC 19 (1906–2023) NM 18 (1980–2025) OR 17 (1961–2022) CT 16 (1990–2021) CO 16 (1980–2019) UT 15 (1987–2024) MS 15 (1993–2012) MN 13 (1977–2016) TN 11 (1984–2024) WI 11 (1993–2026) VA 11 (1966–2019) IA 11 (1947–2026) DC 10 (1963–2024) VT 10 (1978–2026) ND 10 (1989–2021) SD 10 (1978–2025) AZ 9 (1976–2020) IN 9 (1974–2023) KY 8 (1984–2026) OK 8 (1985–2024) MT 7 (1978–2009) KS 6 (1959–2023) WV 6 (1991–2016) SC 5 (1994–2018) AK 4 (1981–2022) WY 4 (1985–1998) RI 4 (1964–2016) ME 4 (1992–2016) ID 4 (1987–2024) HI 3 (1997–2013) NV 3 (1991–2015) AR 3 (1994–2009) NE 2 (1937–1994) NH 2 (1984–1993)

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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