limited form of parental immunity (Illinois) · Go Syfert
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limited form of parental immunity in Illinois

7 Illinois opinions name it 2 courts 1978–2002 0 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
Wallace v. Smythgreen
illappct · 1998 · cited in 2 Illinois opinions naming this issue, 2001–2001
2 sentences

2001Wallace, 301 Ill.App.3d at 80-81 , In Nichol, 192 Ill.2d at 244 , 248 Ill.Dec. 931 , 735 N.E.2d 582 , the supreme court held that a limited form of parental immunity should be available in negligence actions against foster parents.

2001The court in Nichol found that a limited form of parental immunity applied to foster parents despite the fact that “the relationship between a foster parent and a foster child, like the relationship between a teacher and a student, is not permanent and may even be relatively brief.” Nichol, 192 Ill. 2d at 246 ; see also Wallace, 301 Ill.

22

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 (8)

CaseCitedYears
Nichol v. Stass green
ill · 2000
2 sentences

2002JUSTICE FITZGERALD delivered the opinion of the court: The issue in this case is whether, in the wake of our decisions to retain a limited form of parental immunity in Cates v. Cates, 156 Ill. 2d 76 (1993), and to extend this immunity to foster parents in Nichol v. Stass, 192 Ill. 2d 233 (2000), the defendants, a residential child care facility and seven of its employees, enjoyed a similar immunity from the plaintiffs negligence claims after her son died in their care.

2002In my opinion, Nichol v. Stass, 192 Ill. 2d 233 (2000), which extended a limited form of parental immunity to foster parents in negligence actions, is controlling.

52000–2002
Cates v. Cates green
ill · 1993
2 sentences

2002Justice FITZGERALD delivered the opinion of the court: The issue in this case is whether, in the wake of our decisions to retain a limited form of parental immunity in Cates v. Cates, 156 Ill.2d 76 , 189 Ill.Dec. 14 , 619 N.E.2d 715 (1993), and to extend this immunity to foster parents in Nichol v. Stass, 192 Ill.2d 233 , 248 Ill.Dec. 931 , 735 N.E.2d 582 (2000), the defendants, a residential child care facility and seven of its employees, enjoyed a similar immunity from the plaintiff's negligence claims after her son died in their care.

2002JUSTICE FITZGERALD delivered the opinion of the court: The issue in this case is whether, in the wake of our decisions to retain a limited form of parental immunity in Cates v. Cates, 156 Ill. 2d 76 (1993), and to extend this immunity to foster parents in Nichol v. Stass, 192 Ill. 2d 233 (2000), the defendants, a residential child care facility and seven of its employees, enjoyed a similar immunity from the plaintiffs negligence claims after her son died in their care.

32001–2002
Wallace v. Smyth green
illappct · 2001
2 sentences

2002Those are exactly the types of duties and responsibilities found in Cates and Nichol to be inherent to the parent-child relationship. * * * Both Cates and Nichol make clear that what matters most for purposes of extending immunity is whether the party to whom it is being extended exercises a substantial amount of parental discretion in discipline, supervision, and care of minors. * * * [W]e cannot say that there is meaningful difference between foster parents and residential child care institutions such as *984 Maryville so as to preclude the limited form of parental immunity discussed in Cate

2002Those are exactly the types of duties and responsibilities found in Cates and Nichol to be inherent to the parent-child relationship. ***** Both Cates and Nichol make clear that what matters most for purposes of extending immunity is whether the party to whom it is being extended exercises a substantial amount of parental discretion in discipline, supervision, and care of minors. *** [W]e cannot say that there is meaningful difference between foster parents and residential child care institutions such as Maryville so as to preclude the limited form of parental immunity discussed in Cates and N

22002–2002
Commerce Bank v. Augsburger green
illappct · 1997
2 sentences

2001Relying on reasoning developed in Cates v. Cates, 156 Ill.2d 76 , 189 Ill.Dec. 14 , 619 N.E.2d 715 (1993), and Commerce Bank v. Augsburger, 288 Ill.App.3d 510 , 223 Ill.Dec. 872 , 680 N.E.2d 822 (1997), Nichol extends a limited form of parental immunity to foster parents.

2001App. 3d 510 , 680 N.E.2d 822 (1997), Nichol extends a limited form of parental immunity to foster parents.

22001–2001
Goller v. White green
wis · 1963
2 sentences

2000It should be noted that one of the decisions cited favorably by Cates, Goller v. White, 20 Wis. 2d 402 , 122 N.W.2d 193 (1963), recognized a limited form of parental immunity in an action against a foster parent.

2000It should be noted that one of the decisions cited favorably by Cates, Goller v. White, 20 Wis. 2d 402 , 122 N.W.2d 193 (1963), recognized a limited form of parental immunity in an action against a foster parent.

22000–2000
Nudd v. Matsoukas green
ill · 1956
1 sentence

1978(Kobylanski v. Chicago Board of Education (1976), 63 Ill. 2d 165 ; Mroczynski v. McGrath (1966), 34 Ill. 2d 451 ; Nudd v. Matsoukas (1956), 7 Ill. 2d 608 .) In 1965, the General Assembly enacted sections 24—24 and 34—84a of the School Code, which had the effect of extending this limited form of parental immunity to teachers and other certificated educational employees.

11978–1978
Kobylanski v. Chicago Board of Education green
ill · 1976
1 sentence

1978(Kobylanski v. Chicago Board of Education (1976), 63 Ill. 2d 165 ; Mroczynski v. McGrath (1966), 34 Ill. 2d 451 ; Nudd v. Matsoukas (1956), 7 Ill. 2d 608 .) In 1965, the General Assembly enacted sections 24—24 and 34—84a of the School Code, which had the effect of extending this limited form of parental immunity to teachers and other certificated educational employees.

11978–1978
Mroczynski v. McGrath green
ill · 1966
1 sentence

1978(Kobylanski v. Chicago Board of Education (1976), 63 Ill. 2d 165 ; Mroczynski v. McGrath (1966), 34 Ill. 2d 451 ; Nudd v. Matsoukas (1956), 7 Ill. 2d 608 .) In 1965, the General Assembly enacted sections 24—24 and 34—84a of the School Code, which had the effect of extending this limited form of parental immunity to teachers and other certificated educational employees.

11978–1978

Statutes the citing opinions construe

IL § 820 ILCS 305/1 (4)

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

IL 7 (1978–2002) WA 2 (2008–2008)

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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