abuse of process claim (Illinois) · Go Syfert
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abuse of process claim in Illinois

7 Illinois opinions name it 1 courts 1996–2023 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 (8)

CaseFollowedCited
McGrew v. Heinold Commodities, Inc.green
illappct · 1986 · cited in 3 Illinois opinions naming this issue, 2018–2021
2 sentences

2021While the plaintiffs alleged that the defendants misstated or exaggerated the underlying debt at issue – for example, by filing inflated proofs of claim – the validity of the underlying debt is “simply irrelevant to an abuse of process claim.” McGrew, 147 Ill.

2018See id. ("the validity of the underlying debt is simply irrelevant to an abuse of process claim").

23
Landmark Insurance Company v. NIP Groupgreen
illappct · 2011 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023We now turn to the merits of his claim. ¶ 56 We note that while the trial court determined that Florida law should apply to the abuse of process claim, the parties agree that the court should have applied Illinois law because “ ‘[a] choice-of-law determination is required only when a difference in law will make a difference in the outcome.’ ” Landmark American Insurance Co. v. NIP Group, Inc., 2011 IL App (1st) 101155, ¶ 21 (quoting Townsend v. Sears, Roebuck & Co., 227 Ill. 2d 147, 155 (2007)). 20 No. 1-22-0273 “ ‘If the relevant laws of the two states yield essentially the same result regard

11
Gleim v. Robertsgreen
illappct · 2009 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023We now turn to the merits of his claim. ¶ 56 We note that while the trial court determined that Florida law should apply to the abuse of process claim, the parties agree that the court should have applied Illinois law because “ ‘[a] choice-of-law determination is required only when a difference in law will make a difference in the outcome.’ ” Landmark American Insurance Co. v. NIP Group, Inc., 2011 IL App (1st) 101155, ¶ 21 (quoting Townsend v. Sears, Roebuck & Co., 227 Ill. 2d 147, 155 (2007)). 20 No. 1-22-0273 “ ‘If the relevant laws of the two states yield essentially the same result regard

11
Townsend v. Sears, Roebuck and Co.green
ill · 2007 · cited in 1 Illinois opinions naming this issue, 2023–2023
2 sentences

2023We now turn to the merits of his claim. ¶ 56 We note that while the trial court determined that Florida law should apply to the abuse of process claim, the parties agree that the court should have applied Illinois law because “ ‘[a] choice-of-law determination is required only when a difference in law will make a difference in the outcome.’ ” Landmark American Insurance Co. v. NIP Group, Inc., 2011 IL App (1st) 101155, ¶ 21 (quoting Townsend v. Sears, Roebuck & Co., 227 Ill. 2d 147, 155 (2007)). 20 No. 1-22-0273 “ ‘If the relevant laws of the two states yield essentially the same result regard

2023We now turn to the merits of his claim. ¶ 56 We note that while the trial court determined that Florida law should apply to the abuse of process claim, the parties agree that the court should have applied Illinois law because “ ‘[a] choice-of-law determination is required only when a difference in law will make a difference in the outcome.’ ” Landmark American Insurance Co. v. NIP Group, Inc., 2011 IL App (1st) 101155, ¶ 21 (quoting Townsend v. Sears, Roebuck & Co., 227 Ill. 2d 147, 155 (2007)). 20 No. 1-22-0273 “ ‘If the relevant laws of the two states yield essentially the same result regard

11
Doyle v. Shlenskygreen
illappct · 1983 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021While we believe it is likely that Coralynn has pled sufficient facts as to the ulterior motive element as it pertains to Joseph and Amber, we withhold our analysis of that element at this time and, instead, focus on the second element of abuse of process, as we find it determinative to the claims against all defendants. 22 ¶ 83 “The test for sufficiency of the allegations pertaining to the second element is whether process has been used to accomplish some result which is beyond the purview of the process, or which compels the party against whom it is used to do some collateral thing which he

11
Withall v. Capitol Federal Savings of Americagreen
illappct · 1987 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021See also Withall v. Capitol Federal Savings of America, 155 Ill.

11
Holiday Magic, Inc. v. Scottgreen
illappct · 1972 · cited in 1 Illinois opinions naming this issue, 2003–2003
1 sentence

2003Holiday Magic, Inc. v. Scott, 4 Ill.

11
Bank of Lyons v. Schultzgreen
ill · 1980 · cited in 1 Illinois opinions naming this issue, 1996–1996
2 sentences

1996Bank of Lyons v. Schultz, 78 Ill. 2d 235, 241 (1980).

1996Bank of Lyons v. Schultz, 78 Ill.2d 235, 241 , 35 Ill.Dec. 758 , 399 N.E.2d 1286 (1980).

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 (1)

CaseCitedYears
Kumar v. Bornstein green
illappct · 2004
2 sentences

2023App. 3d at 165-66 . ¶ 58 We find that Oppenheim’s claim fails because his complaint does not satisfy the second element of an abuse of process claim, which requires proof “that the process was used to accomplish some result that is beyond the purview of the process.” Id. at 165 .

2021Kumar, 354 Ill.

22021–2023

Statutes the citing opinions construe

IL § 735 ILCS 5/2-615 (4) IL § 735 ILCS 5/2-619 (4) IL § 735 ILCS 5/2-619.1 (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

OH 53 (1994–2025) MA 51 (1986–2026) CA 44 (1986–2026) NY 25 (1986–2026) CT 22 (1991–2025) PA 20 (2001–2025) CO 20 (1986–2026) TX 19 (1993–2025) SC 17 (1994–2026) NM 17 (1987–2024) NV 16 (1986–2022) IN 16 (1994–2025) AL 15 (1981–2024) ME 15 (1984–2023) IA 14 (1982–2021) NC 13 (1986–2025) MO 12 (1993–2022) MT 12 (2000–2024) MS 10 (1999–2025) WA 10 (2008–2026) AZ 10 (1982–2024) RI 8 (1989–2010) MI 8 (1984–2024) LA 8 (1993–2024) AR 8 (1993–2021) VA 8 (1989–2021) KY 7 (2013–2024) HI 7 (1990–2024) UT 7 (2004–2025) IL 7 (1996–2023) KS 6 (1988–2021) FL 6 (1984–2025) NJ 6 (1992–2026) WI 5 (1979–2026) AK 5 (1988–2025) TN 5 (2000–2020) DE 4 (2014–2024) ND 4 (2015–2020) OR 3 (1986–2023) OK 3 (2000–2020) SD 3 (1991–2022) NH 3 (1995–2019) MN 2 (1979–2014) NE 2 (1998–2025)

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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