extension doctrine (Illinois) · Go Syfert
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extension doctrine in Illinois

55 Illinois opinions name it 2 courts 1886–2025 6 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 (11)

CaseFollowedCited
People v. Davisgreen
ill · 1976 · cited in 9 Illinois opinions naming this issue, 1978–2023
2 sentences

2023App. 3d 701, 725 (2009)); see also People v. Davis, 65 Ill. 2d 157 , 164- 65 (1976) (the Illinois Supreme Court held, “In our judgment, the extension of the doctrine of judicial notice to include facts which, while not generally known, are readily verifiable from sources of indisputable 15 that data, only three Illinois counties (Boone, Lake, and Kendall Counties) had no shortage of mental health workers.

2021Further, “[appellate courts] can take judicial notice of the computer docket sheets under [the Illinois Supreme Court’s decision in People v. Davis, 65 Ill. 2d 157 (1976)].” People v. Johnson, 2020 IL App (1st) 171638, ¶ 29 (in Johnson, the appellate court took judicial notice of submitted computer printouts which purported to be copies of the circuit court docket); see also People v. Davis, 65 Ill. 2d 157, 164-65 (1976) (the Illinois Supreme Court held, “In our judgment, the extension of the doctrine of judicial notice to include facts which, while not generally known, are readily verifiable

49
California v. Acevedogreen
scotus · 1991 · cited in 2 Illinois opinions naming this issue, 2020–2022
2 sentences

2022Id. ¶ 30 (citing California v. Acevedo, 500 U.S. 565, 569, 570, 579-80 (1991); United States v. Ross, 456 U.S. 798, 825 (1982)).

2020California v. Acevedo, 500 U.S. 565, 569, 570, 579-80 (1991) (citing Carroll v. United States, 267 U.S. 132, 158-59 (1925); United States v. Ross, 456 U.S. 798, 825 (1982)). 2 However, the trial court here did not reach the issue of whether probable cause existed.

22
United States v. Rossgreen
scotus · 1982 · cited in 2 Illinois opinions naming this issue, 2020–2022
2 sentences

2022Id. ¶ 30 (citing California v. Acevedo, 500 U.S. 565, 569, 570, 579-80 (1991); United States v. Ross, 456 U.S. 798, 825 (1982)).

2020California v. Acevedo, 500 U.S. 565, 569, 570, 579-80 (1991) (citing Carroll v. United States, 267 U.S. 132, 158-59 (1925); United States v. Ross, 456 U.S. 798, 825 (1982)). 2 However, the trial court here did not reach the issue of whether probable cause existed.

22
People v. Johnsongreen
illappct · 2020 · cited in 2 Illinois opinions naming this issue, 2021–2021
2 sentences

2021Further, “[appellate courts] can take judicial notice of the computer docket sheets under [the Illinois Supreme Court’s decision in People v. Davis, 65 Ill. 2d 157 (1976)].” People v. Johnson, 2020 IL App (1st) 171638, ¶ 29 (in Johnson, the appellate court took judicial notice of submitted computer printouts which purported to be copies of the circuit court docket); see also People v. Davis, 65 Ill. 2d 157, 164-65 (1976) (the Illinois Supreme Court held, “In our judgment, the extension of the doctrine of judicial notice to include facts which, while not generally known, are readily verifiable

2021Further, “[appellate courts] can take judicial notice of the computer docket sheets under [the Illinois Supreme Court’s decision in People v. Davis, 65 Ill. 2d 157 (1976)].” People v. Johnson, 2020 IL App (1st) 171638, ¶ 29 (in Johnson, the appellate court took judicial notice of submitted computer printouts which purported to be copies of the circuit court docket); see also People v. Davis, 65 Ill. 2d 157, 164-65 (1976) (the Illinois Supreme Court held, “In our judgment, the extension of the doctrine of judicial notice to include facts which, while not generally known, are readily verifiable

22
Carroll v. United Statesgreen
scotus · 1925 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020California v. Acevedo, 500 U.S. 565, 569, 570, 579-80 (1991) (citing Carroll v. United States, 267 U.S. 132, 158-59 (1925); United States v. Ross, 456 U.S. 798, 825 (1982)). 2 However, the trial court here did not reach the issue of whether probable cause existed.

11
United States v. Jacobsengreen
scotus · 1984 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020See id. ¶ 30 We are mindful that the United States Supreme Court has held, as an extension of the exception to the search warrant requirement for moving vehicles, that the police may search a container or package found in an automobile without a warrant if the search of the automobile is supported by probable cause or if the police have probable cause to believe the package contains contraband or evidence.

11
People v. Villarrealgreen
ill · 1992 · cited in 1 Illinois opinions naming this issue, 2003–2003
2 sentences

2003See Villarreal , 152 Ill. 2d at 378-79 , 604 N.E.2d at 928 .

2003See Villarreal , 152 Ill. 2d at 378-79 , 604 N.E.2d at 928 .

11
State v. Cartergreen
mo · 1982 · cited in 1 Illinois opinions naming this issue, 1995–1995
2 sentences

1995The dissenters observed that Missouri precedent had already applied the attorney-client privilege to defense communications with an insurance adjuster; therefore, the statute did not bar the extension of the privilege to defense-retained psychiatrists. ( Carter, 641 S.W.2d at 64 (Seiler, J., dissenting, joined by Welliver & Bardgett, JJ.).) One of the dissenters noted that the majority's ruling *979 would cause attorneys to render ineffective assistance of counsel, Carter, 641 S.W.2d at 66-67 (Welliver, J., dissenting).

1995The dissenters observed that Missouri precedent had already applied the attorney-client privilege to defense communications with an insurance adjuster; therefore, the statute did not bar the extension of the privilege to defense-retained psychiatrists. ( Carter, 641 S.W.2d at 64 (Seiler, J., dissenting, joined by Welliver & Bardgett, JJ.).) One of the dissenters noted that the majority's ruling *979 would cause attorneys to render ineffective assistance of counsel, Carter, 641 S.W.2d at 66-67 (Welliver, J., dissenting).

11
Naguit v. Selckegreen
illappct · 1989 · cited in 1 Illinois opinions naming this issue, 1993–1993
1 sentence

1993App. 3d 80, 83 , 539 N.E.2d 1353, 1355 (reversing the granting of a preliminary injunction prohibiting the use of medical records in a disciplinary action by analogizing to the exclusionary rule and finding no support for the extension of the rule to an administrative proceeding).

11
May Department Stores Co. v. Teamsters Union Local No. 743green
ill · 1976 · cited in 1 Illinois opinions naming this issue, 1983–1983
11
Lombard Park District v. Chicago Title & Trust Co.green
illappct · 1968 · 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 (50)

CaseCitedYears
Mahurin v. Lockhart green
illappct · 1979
2 sentences

2006Given the clearly rural nature of the property in question, neither the Restatement exception for possessors of urban land (see Restatement (Second) of Torts '363(2), at 258 (1965)), nor the extension of that exception to owners of residential land (see Mahurin, 71 Ill.

2006Given the clearly rural nature of the property in question, neither the Restatement exception for possessors of urban land (see Restatement (Second) of Torts § 363(2), at 258 (1965)), nor the extension of that exception to owners of residential land (see Mahurin, 71 Ill.

22006–2006
General Insurance Co. of America v. Robert B. McManus, Inc. green
illappct · 1995
2 sentences

1999General Insurance, 272 Ill.

1999General Insurance, 272 Ill.

21999–1999
Dolatowski v. Life Printing & Publishing Co. green
illappct · 1990
2 sentences

1998Dolatowski , 197 Ill.

1998Dolatowski, 197 Ill.

21998–1998
People v. Bronson green
illappct · 1991
2 sentences

1996People v. Bronson (1991), 216 Ill.

1993People v. Bronson (1991), 216 Ill.

21993–1996
Cesena v. Du Page County green
illappct · 1990
2 sentences

1995(See Cesena v. Du Page County (1990), 201 Ill.App.3d 96, 112 , 146 Ill.Dec. 1044 , 558 N.E.2d 1378 , rev'd on other grounds (1991), 145 Ill.2d 32 , 163 Ill.Dec. 911 , 582 N.E.2d 177 .) Moreover, matters a client intends to disclose to third parties who are not agents of either the attorney or the client are not treated as privileged. ( In re Himmel (1988), 125 Ill.2d 531, 542 , 127 Ill.Dec. 708 , 533 N.E.2d 790 ; Cesena, 201 Ill.App.3d at 112 , 146 Ill.Dec. 1044 , 558 N.E.2d 1378 .) In Indiana, the defendant appeared in open court represented by Work and used the name Gerald Bailey.

1995(See Cesena v. Du Page County (1990), 201 Ill.

21995–1995
People v. Williams green
ill · 1983
2 sentences

1995(People v. Williams (1983), 97 Ill. 2d 252 , 454 N.E.2d 220 .) Illinois courts have held that the attorney-client privilege does not extend to the identity of the client unless the extension of the privilege is shown to be in the public interest or if it appears that the client will be prejudiced in "some substantial way” by the disclosure.

1995(People v. Williams (1983), 97 Ill. 2d 252 , 454 N.E.2d 220 .) Illinois courts have held that the attorney-client privilege does not extend to the identity of the client unless the extension of the privilege is shown to be in the public interest or if it appears that the client will be prejudiced in "some substantial way” by the disclosure.

21995–1995
Phillips v. People green
colo · 1969
2 sentences

1981In the absence of such an extension of the rule in Miranda by the Supreme Court, this court shall continue to adhere to the rule that in order for a search with consent to be reasonable the consent must be voluntary, and that the question of whether the consent was freely and intelligently given is to be determined according to the circumstances in each case.” (Phillips v. People (1969), 170 Colo. 520, 527-28 , 462 P.2d 594, 597 .) We agree with the Colorado Supreme Court that lacking clearer direction from the Supreme Court, our proper inquiry is into the voluntariness of the consent to searc

1981In the absence of such an extension of the rule in Miranda by the Supreme Court, this court shall continue to adhere to the rule that in order for a search with consent to be reasonable the consent must be voluntary, and that the question of whether the consent was freely and intelligently given is to be determined according to the circumstances in each case.” (Phillips v. People (1969), 170 Colo. 520, 527-28 , 462 P.2d 594, 597 .) We agree with the Colorado Supreme Court that lacking clearer direction from the Supreme Court, our proper inquiry is into the voluntariness of the consent to searc

21981–1994
Peterson v. Lou Bachrodt Chevrolet Co. green
ill · 1975
2 sentences

1992App. 3d at 257 , citing Peterson v. Lou Bachrodt Chevrolet Co. (1975), 61 Ill. 2d 17 , 329 N.E.2d 785 .) Domine further opined that the public policy of Illinois does not favor the extension of the doctrine of strict liability to a successor corporation.

1992App. 3d at 257 , citing Peterson v. Lou Bachrodt Chevrolet Co. (1975), 61 Ill. 2d 17 , 329 N.E.2d 785 .) Domine further opined that the public policy of Illinois does not favor the extension of the doctrine of strict liability to a successor corporation.

21991–1992
Raymond Leannais and Catherine Leannais v. Cincinnati, Incorporated and Cincinnati-Forte Company and Liberty Mutual Insurance Company green
ca7 · 1977
2 sentences

1992Hernandez emphasized an additional reason to reject the “product line” exception in reliance on statements enunciated in Leannais v. Cincinnati, Inc. (7th Cir. 1977), 565 F.2d 437 .

1991In Hernandez this court found an additional reason to reject the product line exception in reliance on statements enunciated in Leannais v. Cincinnati, Inc. (7th Cir. 1977), 565 F.2d 437 .

21991–1992
Kramer v. Chicago Title & Trust Co. green
illappct · 1979
2 sentences

1989(Kramer v. Chicago Title & Insurance Co. (1979), 69 Ill.

1983App. 3d 1015, 1018 , 387 N.E.2d 1105 : “Estoppel by verdict or collateral estoppel is an extension of the doctrine of res judicata. [Citation.] It is based on the principle that a question once adjudicated by a proper court is to be considered as finally settled and conclusive on the unsuccessful parties. [Citation.] Estoppel by verdict or collateral estoppel is applicable even where the parties are not arrayed on opposite sides in prior litigation or formal issues have not been drawn up between them. [Citations.]” (See also Creeco Co. v. Northern Illinois Gas Co. (1966), 73 Ill.

21983–1989
People v. Fife green
ill · 1979
2 sentences

1981Respondent appears to seek an extension of the rule announced in People v. Fife (1979), 76 Ill. 2d 418 , 392 N.E.2d 1345 .

1981Respondent appears to seek an extension of the rule announced in People v. Fife (1979), 76 Ill. 2d 418 , 392 N.E.2d 1345 .

21981–1981
People v. Valentine green
illappct · 1965
2 sentences

1970In People v. Valentine, 60 Ill App2d 339, 208 NE2d 595 , this court noted at page 348 that the then existing rule was “. . . if a case in which constitutional questions were raised was transferred to this court, it was presumed that the Supreme Court had determined that the constitutional questions were not genuine or that the questions were not material to the disposition of the appeal. [Citing cases.] There now must be an extension of this rule because of the possible alternative presumption that the constitutional questions are deemed well settled by the prior decisions of the court.” We ca

1970App.2d 339 , 208 NE2d 595 , this court noted at page 348 that the then existing rule was "... if a case in which constitutional questions were raised was transferred to this court, it was presumed that the Supreme Court had determined that the constitutional questions were not genuine or that the questions were not material to the disposition of the appeal. [Citing cases.] There now must be an extension of this rule because of the possible *356 alternative presumption that the constitutional questions are deemed well settled by the prior decisions of the court." We cannot hold that such a tran

21970–1970
Dralle v. Ruder green
ill · 1988
1 sentence

2025Dralle, 124 Ill. 2d at 69-70 .

12025–2025
People v. Burton green
illappct · 2012
1 sentence

2020People v. Burton, 2012 IL App (2d) 110769, ¶ 15 .

12020–2020
Lutz v. Lutz green
illappct · 2000
2 sentences

2018App. 3d at 287 -88 , 245 Ill.Dec. 877 , 728 N.E.2d 1234 . ¶ 19 On appeal, the respondent contended that the extension was error because, when the court entered it, the plenary order had already expired.

2018App. 3d at 287 -88 , 245 Ill.Dec. 877 , 728 N.E.2d 1234 . ¶ 19 On appeal, the respondent contended that the extension was error because, when the court entered it, the plenary order had already expired.

12018–2018
People v. White green
illappct · 2000
1 sentence

2015Neither the Davis nor Scott court conditioned their sanction of the use of judicial notice upon the level of proof required.” White, 311 Ill.

12015–2015
Cesena v. Du Page County green
ill · 1991
2 sentences

1995(See Cesena v. Du Page County (1990), 201 Ill.App.3d 96, 112 , 146 Ill.Dec. 1044 , 558 N.E.2d 1378 , rev'd on other grounds (1991), 145 Ill.2d 32 , 163 Ill.Dec. 911 , 582 N.E.2d 177 .) Moreover, matters a client intends to disclose to third parties who are not agents of either the attorney or the client are not treated as privileged. ( In re Himmel (1988), 125 Ill.2d 531, 542 , 127 Ill.Dec. 708 , 533 N.E.2d 790 ; Cesena, 201 Ill.App.3d at 112 , 146 Ill.Dec. 1044 , 558 N.E.2d 1378 .) In Indiana, the defendant appeared in open court represented by Work and used the name Gerald Bailey.

1995(See Cesena v. Du Page County (1990), 201 Ill.App.3d 96, 112 , 146 Ill.Dec. 1044 , 558 N.E.2d 1378 , rev'd on other grounds (1991), 145 Ill.2d 32 , 163 Ill.Dec. 911 , 582 N.E.2d 177 .) Moreover, matters a client intends to disclose to third parties who are not agents of either the attorney or the client are not treated as privileged. ( In re Himmel (1988), 125 Ill.2d 531, 542 , 127 Ill.Dec. 708 , 533 N.E.2d 790 ; Cesena, 201 Ill.App.3d at 112 , 146 Ill.Dec. 1044 , 558 N.E.2d 1378 .) In Indiana, the defendant appeared in open court represented by Work and used the name Gerald Bailey.

11995–1995
In Re Himmel green
ill · 1988
2 sentences

1995(See Cesena v. Du Page County (1990), 201 Ill.App.3d 96, 112 , 146 Ill.Dec. 1044 , 558 N.E.2d 1378 , rev'd on other grounds (1991), 145 Ill.2d 32 , 163 Ill.Dec. 911 , 582 N.E.2d 177 .) Moreover, matters a client intends to disclose to third parties who are not agents of either the attorney or the client are not treated as privileged. ( In re Himmel (1988), 125 Ill.2d 531, 542 , 127 Ill.Dec. 708 , 533 N.E.2d 790 ; Cesena, 201 Ill.App.3d at 112 , 146 Ill.Dec. 1044 , 558 N.E.2d 1378 .) In Indiana, the defendant appeared in open court represented by Work and used the name Gerald Bailey.

1995(See Cesena v. Du Page County (1990), 201 Ill.App.3d 96, 112 , 146 Ill.Dec. 1044 , 558 N.E.2d 1378 , rev'd on other grounds (1991), 145 Ill.2d 32 , 163 Ill.Dec. 911 , 582 N.E.2d 177 .) Moreover, matters a client intends to disclose to third parties who are not agents of either the attorney or the client are not treated as privileged. ( In re Himmel (1988), 125 Ill.2d 531, 542 , 127 Ill.Dec. 708 , 533 N.E.2d 790 ; Cesena, 201 Ill.App.3d at 112 , 146 Ill.Dec. 1044 , 558 N.E.2d 1378 .) In Indiana, the defendant appeared in open court represented by Work and used the name Gerald Bailey.

11995–1995
People v. Wegman green
illappct · 1981
2 sentences

1994In the absence of such an extension of the rule in Miranda by the Supreme Court, this court shall continue to adhere to the rule that in order for a search with consent to be reasonable the consent must be voluntary, and that the question of whether the consent was freely and intelligently given is to be determined according to the circumstances in each case.’ ” (Wegman, 101 Ill.

1994App. 3d at 638 , 428 N.E.2d at 640-41 , quoting Phillips v. People (1969), 170 Colo. 520, 527-28 , 462 P.2d 594, 597 .) The appellate court then found defendant’s consent voluntary.

11994–1994
Farmers' Mutual Fire & Lightning Insurance v. Crowley green
mo · 1945
2 sentences

1992The Missouri Supreme Court in Farmers Mutual Fire & Lightning Insurance Co. v. Crowley (1945), 354 Mo. 649 , 190 S.W.2d 250 , stated that a life tenant has a duty to pay taxes, make ordinary repairs, and keep down interest on encumbrances and his failure to perform these duties falls under the extension of the rule which prohibits waste.

1992The Missouri Supreme Court in Farmers Mutual Fire & Lightning Insurance Co. v. Crowley (1945), 354 Mo. 649 , 190 S.W.2d 250 , stated that a life tenant has a duty to pay taxes, make ordinary repairs, and keep down interest on encumbrances and his failure to perform these duties falls under the extension of the rule which prohibits waste.

11992–1992
Bond v. Lockwood neutral
ill · 1864
11992–1992
Pasulka v. Koob green
illappct · 1988
1 sentence

1992In Bond v. Lockwood, the Illinois Supreme Court cited the English common law definition of waste: “Any act or omission which diminished the value of the estate or its income, or increased the burdens upon it or impaired the evidence of title thereto, was considered waste.” (Bond v. Lockwood (1864), 33 Ill. 212, 221 .) More recently: “Waste occurs when someone who lawfully has possession of real estate destroys it, misuses it, alters it or neglects it so that the interest of persons having a subsequent right to possession is prejudiced in some way or there is a diminution in the value of the la

11992–1992
Allison v. Shell Oil Co. green
ill · 1986
11991–1991
Sargent v. Interstate Bakeries, Inc. green
illappct · 1967
11991–1991
Van C. Argiris Co. v. Caine Steel Co. green
illappct · 1974
11985–1985
Walsh v. Union Oil Co. of California green
ill · 1972
11983–1983
Rickey v. Chicago Transit Authority green
illappct · 1981
11983–1983
Creeco Co. v. Northern Illinois Gas Co. neutral
illappct · 1966
11983–1983
Groome v. Freyn Engineering Co. green
ill · 1940
11982–1982
Kokinis v. Kotrich green
illappct · 1979
11982–1982
Brokerage Resources, Inc. v. Jordan green
illappct · 1980
11982–1982
Sottiaux v. Bean neutral
ill · 1950
11982–1982
In Re WS green
ill · 1980
11980–1980
Wong Sun v. United States green
scotus · 1963
11978–1978
Galluccio v. the Hertz Corp. green
illappct · 1971
11978–1978
United States v. Calandra green
scotus · 1974
11978–1978
Leonard v. Autocar Sales & Service Co. green
ill · 1945
11977–1977
United States v. Petterson Lighterage & Towing Corp. green
scotus · 1946
11977–1977
United States v. Everett Edmond Rhodes green
ca7 · 1968
11972–1972
The People v. Moses green
ill · 1957
11968–1968

Where else courts name it

PA 94 (1898–2023) CA 92 (1897–2025) NY 76 (1841–2024) MA 63 (1936–2026) IL 55 (1886–2025) TX 54 (1888–2026) WI 52 (1951–2026) MD 38 (1911–2018) TN 34 (1933–2025) GA 31 (1909–2025) LA 29 (1942–2022) FL 24 (1968–2025) NJ 24 (1948–2026) MI 23 (1896–2024) KY 22 (1907–2025) WA 19 (1933–2024) CT 19 (1912–2019) OH 19 (1905–2024) IN 17 (1884–2003) AL 17 (1845–2011) IA 15 (1926–2024) DE 15 (1928–2024) KS 15 (1915–2022) MO 15 (1875–2018) AZ 11 (1965–2024) OR 11 (1938–2024) NH 10 (1970–2017) WY 9 (1978–1992) WV 9 (1922–2015) MN 9 (1928–2023) NC 9 (1910–2016) OK 9 (1928–2023) NE 8 (1931–2017) NM 8 (1946–2026) HI 8 (1908–2008) SD 7 (1927–2024) NV 7 (1951–2020) VA 7 (1934–2011) UT 7 (1953–2015) ME 7 (1942–2018) CO 6 (1900–2008) AR 6 (1925–2013) MS 5 (1961–2011) DC 5 (1974–2007) RI 5 (1949–1995) VT 4 (1854–2020) SC 4 (1937–2014) ND 4 (1908–2007) ID 3 (1989–2012) AK 2 (1970–1979)

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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