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6 Illinois opinions name it 2 courts 2019–2026 4 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.
| Case | Followed | Cited |
|---|---|---|
Illinois Glass Co. v. Chicago Telephone Co.green2 sentences2026“The common-law voluntary payment doctrine embodies the ancient and ‘universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.’ ” McIntosh v. Walgreens Boots Alliance, Inc., 2019 IL 123626, ¶ 22 (quoting Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908)). 2021Therefore, the voluntary payment doctrine does not apply to this case. ¶ 22 “The common-law voluntary payment doctrine embodies the ancient and ‘universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.’ ” McIntosh v. Walgreens Boots Alliance, Inc., 2019 IL 123626, ¶ 22 (quoting Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908)). | 4 | 4 |
McIntosh v. Walgreens Boots Alliance, Inc.green2 sentences2026“The common-law voluntary payment doctrine embodies the ancient and ‘universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.’ ” McIntosh v. Walgreens Boots Alliance, Inc., 2019 IL 123626, ¶ 22 (quoting Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908)). 2026Therefore, SIH argues, the fraud deprived SIH of the knowledge required to apply the voluntary payment doctrine. ¶ 51 In evaluating the parties’ arguments, we note that the Illinois Supreme Court summarized the voluntary payment doctrine as it exists in Illinois in McIntosh v. Walgreens Boots Alliance, Inc., 2019 IL 123626 , ¶¶ 22-24, where it stated: 18 “The common-law voluntary payment doctrine embodies the ancient and ‘universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recov | 3 | 4 |
Vine Street Clinic v. HealthLink, Inc.green2 sentences2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). -6- ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial 2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial Ser | 2 | 2 |
Geary v. Dominick's Finer Foods, Inc.green2 sentences2019King, 215 Ill. 2d at 28, 30 ; Illinois Graphics, 159 Ill. 2d at 497 ; Geary v. Dominick’s Finer Foods, Inc., 129 Ill. 2d 389, 393-94 (1989); Freund, 114 Ill. 2d at 79 ; Getto, 86 Ill. 2d at 49 ; Illinois Glass Co., 234 Ill. at 541 ; Yates, 200 Ill. at 207 . ¶ 24 In addition to compulsion or duress, other recognized exceptions to the voluntary payment doctrine include fraud or misrepresentation or mistake of a material fact. 2019King, 215 Ill. 2d at 28, 30 ; Illinois Graphics, 159 Ill. 2d at 497 ; Geary v. Dominick’s Finer Foods, Inc., 129 Ill. 2d 389, 393-94 (1989); Freund, 114 Ill. 2d at 79 ; Getto, 86 Ill. 2d at 49 ; Illinois Glass Co., 234 Ill. at 541 ; Yates, 200 Ill. at 207 . ¶ 24 In addition to compulsion or duress, other recognized exceptions to the voluntary payment doctrine include fraud or misrepresentation or mistake of a material fact. | 2 | 2 |
Freund v. Avis Rent-A-Car System, Inc.green2 sentences2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). -6- ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial 2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial Ser | 2 | 2 |
Kanter & Eisenberg v. Madison Associatesgreen2 sentences2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). -6- ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial 2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial Ser | 2 | 2 |
Getto v. City of Chicagogreen2 sentences2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). -6- ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial 2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial Ser | 2 | 2 |
Elston v. City of Chicagogreen2 sentences2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). -6- ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial 2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial Ser | 2 | 2 |
Yates v. Royal Insurancegreen2 sentences2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). -6- ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial 2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial Ser | 2 | 2 |
King v. First Capital Financial Services Corp.green2 sentences2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). -6- ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial 2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial Ser | 2 | 2 |
Harris v. ChartOnegreen1 sentence2026Therefore, SIH argues, the fraud deprived SIH of the knowledge required to apply the voluntary payment doctrine. ¶ 51 In evaluating the parties’ arguments, we note that the Illinois Supreme Court summarized the voluntary payment doctrine as it exists in Illinois in McIntosh v. Walgreens Boots Alliance, Inc., 2019 IL 123626 , ¶¶ 22-24, where it stated: 18 “The common-law voluntary payment doctrine embodies the ancient and ‘universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recov | 1 | 1 |
Jursich v. ARLINGTON HTS FED. SAV. & LOANgreen1 sentence2026App. 3d 878, 882 (2005), explained that where “the facts were not obscured or inaccessible but, rather, [where] the plaintiff’s lack of knowledge could be attributed to its lack of investigation into the defendant’s claim of liability and the basis upon which the defendant was seeking the [payment]” that the plaintiff’s lack of knowledge was “no exception to the voluntary-payment doctrine.” Thus, this court ruled that the plaintiff could not establish the required mistake of fact or fraud required to trigger the exceptions to the voluntary payment doctrine. ¶ 53 Similarly, in Jursich v. Arling | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Illinois Graphics Co. v. Nickum
green
2 sentences2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). -6- ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial 2019Section 2 requires, however, that the misrepresentation must relate to a material fact. 815 ILCS 505/2 (West 2014). ¶ 22 The common-law voluntary payment doctrine embodies the ancient and “universally recognized rule that money voluntarily paid under a claim of right to the payment and with knowledge of the facts by the person making the payment cannot be recovered back on the ground that the claim was illegal.” Illinois Glass Co. v. Chicago Telephone Co., 234 Ill. 535, 541 (1908); see also Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 298 (2006); King v. First Capital Financial Ser | 2 | 2019–2019 |
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.
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.