absurd results doctrine (Illinois) · Go Syfert
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absurd results doctrine in Illinois

6 Illinois opinions name it 2 courts 2003–2021 1 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 (4)

CaseFollowedCited
Hasler v. Industrial Commissiongreen
ill · 1983 · cited in 2 Illinois opinions naming this issue, 2015–2016
2 sentences

2016Hasler v. Industrial Comm’n, 97 Ill. 2d 46, 52 (1983) (holding that the purpose of the Act is to make an injured employee whole). ¶ 31 Indeed, the contrary interpretation would run afoul of the absurd-results rule, which states that we must presume the legislature did not intend an absurd or unjust result when it enacted -7- a statute.

2015Hasler v. Industrial Comm’n, 97 Ill. 2d 46, 52 (1983) (holding that the purpose of the Act is to make an injured employee whole). ¶ 31 Indeed, the contrary interpretation would run afoul of the absurd-results rule, which states that we must presume the legislature did not intend an absurd or unjust result when it enacted a statute.

22
Hubble v. Bi-State Development Agencygreen
ill · 2010 · cited in 2 Illinois opinions naming this issue, 2015–2016
2 sentences

2016Hubble v. Bi-State Development Agency of the Illinois-Missouri Metropolitan District, 238 Ill. 2d 262, 283 (2010).

2015Hubble v. Bi-State Development Agency of the Illinois-Missouri Metropolitan District, 238 Ill. 2d 262, 283 (2010).

22
Taylor-Hurley v. Mingo County Board of Educationgreen
wva · 2001 · cited in 2 Illinois opinions naming this issue, 2003–2003
2 sentences

2003As the West Virginia Supreme Court explained in Taylor-Hurley v. Mingo County Board of Education, 209 W.Va. 780, 788 , 551 S.E.2d 702, 710 (2001), "[t]he absurd results doctrine merely permits a court to favor an otherwise reasonable construction of the statutory text over a more literal interpretation where the latter would produce a result demonstrably at odds with any conceivable legislative purpose. [Citation.] It does not, however, license a court to simply ignore or rewrite statutory language on the basis that, as written, it produces an undesirable policy result." I also note the cautio

2003Va. 780, 788 , 551 S.E.2d 702, 710 (2001), “[t]he absurd results doctrine merely permits a court to favor an otherwise reasonable construction of the statutory text over a more literal interpretation where the latter would produce a result demonstrably at odds with any conceivable legislative purpose. [Citation.] It does not, however, license a court to simply ignore or rewrite statutory language on the basis that, as written, it produces an undesirable policy result.” I also note the cautionary statement in Sutherland on Statutory Construction that “the absurd results doctrine should be used

22
In Re Donald AGgreen
ill · 2006 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021See In re Donald A.G., 221 Ill. 2d 234, 246 (2006) (noting a court is not bound by the literal language of the statute if it would lead to absurd or unjust results not contemplated); see also supra ¶ 21 (“This outcome is unacceptable; we must presume the legislature did not intend an inconvenience.”). ¶ 31 In order to avoid either an absurd result or “inconvenience,” I would find that the party requesting the summons must engage in a reasonable search to ascertain whether the party to be served is located in Cook County.

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
Church of the Holy Trinity v. United States green
scotus · 1892
2 sentences

2008The confusion might have arisen because of a quotation defendant used from Church of the Holy Trinity, where the Supreme Court stated that “frequently words of general meaning are used in a statute, words broad enough to include an act in question, and yet a consideration of the whole legislation, or of the circumstances surrounding its enactment, or of the absurd results which follow from giving such broad meaning to the words, makes it unreasonable to believe that the legislator intended to include the particular act.” (Emphases added.) Church of the Holy Trinity, 143 U.S. at 459 , 36 L.

2008The confusion might have arisen because of a quotation defendant used from Church of the Holy Trinity, where the Supreme Court stated that “frequently words of general meaning are used in a statute, words broad enough to include an act in question, and yet a consideration of the whole legislation, or of the circumstances surrounding its enactment, or of the absurd results which follow from giving such broad meaning to the words, makes it unreasonable to believe that the legislator intended to include the particular act.” (Emphases added.) Church of the Holy Trinity, 143 U.S. at 459 , 36 L.

12008–2008

Where else courts name it

MI 18 (2003–2025) IA 17 (2011–2019) IL 6 (2003–2021) VT 6 (2005–2026) UT 4 (2007–2024) NE 3 (2020–2025) TX 2 (2015–2019) DE 2 (2007–2020) OR 2 (1999–1999)

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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