estate claim (Illinois) · Go Syfert
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estate claim in Illinois

48 Illinois opinions name it 2 courts 1903–2025 12 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 (16)

CaseFollowedCited
Waughop v. Bartlettgreen
ill · 1896 · cited in 2 Illinois opinions naming this issue, 2022–2022
2 sentences

2022See Waughop, 165 Ill. at 129 .

2022See Waughop, 165 Ill. at 129 .

22
ABN AMRO Mortgage Group Inc. v. McGahangreen
ill · 2010 · cited in 2 Illinois opinions naming this issue, 2022–2022
2 sentences

2022See McGahan, 237 Ill. 2d at 535-36 . ¶ 26 However, in holding that a lapsed claim against a decedent’s estate did not bar a separate foreclosure action, Waughop did not expressly base its conclusion on its characterization of a foreclosure case as an in rem proceeding.

2022See McGahan, 237 Ill. 2d at 535-36 . ¶ 26 However, in holding that a lapsed claim against a decedent’s estate did not bar a separate foreclosure action, Waughop did not expressly base its conclusion on its characterization of a foreclosure case as an in rem proceeding.

22
In Re Estate of Minskygreen
illappct · 1978 · cited in 2 Illinois opinions naming this issue, 1999–1999
2 sentences

1999See In re Estate of Minsky , 59 Ill.

1999See In re Estate of Minsky, 59 Ill.

22
Both v. Nelsongreen
ill · 1964 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024“Where it appears that an error did not affect the outcome below, or where the court can see from the entire record that no injury has been done, the judgment or decree will not be disturbed.” Both v. Nelson, 31 Ill. 2d 511, 514 (1964); accord Simmons v. Garces, 198 Ill. 2d 541, 566-67 (2002).

11
Harris Trust & Savings Bank v. Donovangreen
ill · 1991 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024Harris Trust & Savings Bank v. Donovan, 145 Ill. 2d 166, 172 (1991).

11
Simmons v. Garcesgreen
ill · 2002 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024“Where it appears that an error did not affect the outcome below, or where the court can see from the entire record that no injury has been done, the judgment or decree will not be disturbed.” Both v. Nelson, 31 Ill. 2d 511, 514 (1964); accord Simmons v. Garces, 198 Ill. 2d 541, 566-67 (2002).

11
Hall v. Gillinsgreen
ill · 1958 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023However, the Estate mischaracterizes (1) the effect that the presumption of loss of society has on wrongful death proceedings, (2) the trial court’s written order denying the Estate’s motion for a new trial, and (3) the strength of the Estate’s evidence. ¶ 134 Although the Estate correctly asserts that the presumption of pecuniary injury, on its own, is sufficient to sustain a verdict awarding substantial damages (Hall v. Gillins, 13 Ill. 2d 26, 31 (1958)), that presumption does not require the jury to award damages.

11
Flynn v. Vancilgreen
ill · 1968 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023See 740 ILCS 180/2(a) (West 2020) (“[T]he jury may give such damages as they shall deem a fair and just compensation ***.” (Emphasis added.)); see also Flynn v. Vancil, 41 Ill. 2d 236, 240 , 242 - 30 - N.E.2d 237 (1968) (“Implicit in the right to weigh the presumption is the right to give it no weight at all.”).

11
Leonardi v. Loyola University of Chicagogreen
ill · 1995 · cited in 1 Illinois opinions naming this issue, 2013–2013
1 sentence

2013The evidence may be slight; a reviewing court may not reweigh it or determine if it should lead to a particular conclusion.” Leonardi v. Loyola University of Chicago, 168 Ill. 2d 83, 100 (1995). ¶ 131 Bovis first claims that the trial court abused its discretion by allowing a specific provision into the Estate’s issue instructions.

11
Minikon v. Escobedogreen
illappct · 2001 · cited in 1 Illinois opinions naming this issue, 2012–2012
1 sentence

2012If a party elects to have a special representative appointed under this paragraph (2), the recovery shall be limited to the proceeds of any liability insurance protecting the estate and shall not bar the estate from enforcing any claims that might have been available to it as counterclaims. (c) If a party commences an action against a deceased person whose death is unknown to the party before the expiration of the time limited for the commencement thereof, and the cause of action survives, and is not otherwise barred, the action may be commenced against the deceased person’s personal represent

11
Augustus v. Estate of Somersgreen
illappct · 1996 · cited in 1 Illinois opinions naming this issue, 2012–2012
11
Pufahl v. Estate of Parksgreen
scotus · 1936 · cited in 1 Illinois opinions naming this issue, 2007–2007
11
In Re Estate of Newcombgreen
illappct · 1972 · cited in 1 Illinois opinions naming this issue, 2007–2007
11
Illinois Public Aid Commission v. Sandersongreen
ill · 1951 · cited in 1 Illinois opinions naming this issue, 2007–2007
11
In Re Estate of Garrettgreen
illappct · 1967 · cited in 1 Illinois opinions naming this issue, 1977–1977
11
Ragen v. Bennigsengreen
illappct · 1956 · cited in 1 Illinois opinions naming this issue, 1974–1974
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 (43)

CaseCitedYears
Estate of Glogovsek v. Weck green
illappct · 1993
2 sentences

2018See 755 ILCS 5/2-1, 2-8 (West 2014); Glogovsek, 248 Ill.

2017See 755 ILCS 5/2-1, 2-8 (West 2014); Glogovsek , 248 Ill.

22017–2018
Maple v. Gustafson green
ill · 1992
2 sentences

2016When considering a motion for a new trial, the trial court, after weighing the evidence, will set aside a jury’s verdict and order a new trial only “ ‘if the verdict is contrary to the manifest weight of the evidence.’ ” Id. at 454 (quoting Mizowek, 64 Ill. 2d at 310 ).

2015When considering a motion for a new trial, the trial court, after weighing the evidence, will set aside a jury's verdict and order a new trial only " 'if the verdict is contrary to the manifest weight of the evidence.' " Id. at 454 (quoting Mizowek, 64 Ill. 2d at 310 ).

22015–2016
Mizowek v. De Franco green
ill · 1976
2 sentences

2016When considering a motion for a new trial, the trial court, after weighing the evidence, will set aside a jury’s verdict and order a new trial only “ ‘if the verdict is contrary to the manifest weight of the evidence.’ ” Id. at 454 (quoting Mizowek, 64 Ill. 2d at 310 ).

2015When considering a motion for a new trial, the trial court, after weighing the evidence, will set aside a jury's verdict and order a new trial only " 'if the verdict is contrary to the manifest weight of the evidence.' " Id. at 454 (quoting Mizowek, 64 Ill. 2d at 310 ).

22015–2016
Chenal v. Diersen green
illappct · 1947
2 sentences

2001Given this conclusion, the trial court was within its discretionary authority to demand that plaintiff prove her claim. (footnote: 2) Nonetheless, in opposition to this determination, plaintiff cites In re Estate of Brauns , 330 Ill.

2001Given this conclusion, the trial court was within its discretionary authority to demand that plaintiff prove her claim. 2 Nonetheless, in opposition to this determination, plaintiff cites In re Estate of Brauns, 330 Ill.

22001–2001
In Re Estate of Hoheiser green
illappct · 1981
2 sentences

1993App. 3d 1077 , 424 N.E.2d 25 .) Thus, if Knott’s payment of Hines’ attorney fees was an estate claim, it should have been barred from payment because it was filed more than six months after letters of office issued to Miles.

1993(Ill.Rev.Stat.1991, ch. 110½, par. 18-12; In re Estate of Hoheiser (1981), 97 Ill.App.3d 1077 , 53 Ill.Dec. 612 , 424 N.E.2d 25 .) Thus, if Knott's payment of Hines' attorney fees was an estate claim, it should have been barred from payment because it was filed more than six months after letters of office issued to Miles.

21993–1993
Christiansen v. Christiansen green
calctapp · 1967
2 sentences

1987First, a court should consider the permanence of the incompetent’s condition. ( 248 Cal. App. 2d at 424-25 , 56 Cal. Rptr. at 523 .) Since it had been established that Christiansen’s condition was considered permanent, the court declined to consider whether the condition rendering the ward incompetent is a prerequisite to the invocation of the substituted judgment doctrine.

1987First, a court should consider the permanence of the incompetent’s condition. ( 248 Cal. App. 2d at 424-25 , 56 Cal. Rptr. at 523 .) Since it had been established that Christiansen’s condition was considered permanent, the court declined to consider whether the condition rendering the ward incompetent is a prerequisite to the invocation of the substituted judgment doctrine.

21987–1987
Parker v. Gray green
ill · 1925
2 sentences

1955Brown v. Brown, 329 Ill. 198 ; Parker v. Gray, 317 Ill. 468 ; Murdock v. Murdock, 219 Ill. 123 ; Hessick v. Hessick, 169 Ill. 486 .

1927(Parker v. Gray, 317 Ill. 468 ; Slater v. Slater, 310 id. 454; Landes v. Landes, 268 id. 11; Warner v. Warner, 235 id. 448.) The master found that no evidence had been introduced to show that appellee knew the nature, character, value or extent of Blackburn’s property or that the same had been disclosed to her before executing the agreement, and that the provisions made for her in the contract were inadequate, harsh, unreasonable and disproportionate.

21927–1955
Russell v. Hubbard green
ill · 1871
2 sentences

1917(Hall v. Hale, 202 Ill. 326 .) And so it was held in Russell v. Hubbard, 59 Ill. 335 , that the amount stated as the alleged indebtedness in a claim filed against an estate should be given the same effect as an ad damnum in a declaration.

1903Stat. 1896, p. 293.) In Russell v. Hubbard, 59 Ill. 335 , we held that the amount set forth as the alleged indebtedness in a claim filed against an estate should be given like effect as an ad damnum in a declaration, and that the amount of the .recovery should be limited accordingly.

21903–1917
Insurance Co. of North America v. J. L. Hubbard Co. green
illappct · 1974
1 sentence

2025Hubbard Co. Id.

12025–2025
In re: Estate of Frain green
illappct · 2025
2 sentences

2025We affirm. 2025 IL App (2d) 240780 ¶2 I.

2025Thus, this evidence is not entitled to great weight, other than to show that Dorothy and Villanueva had many jointly held accounts at the bank, which supports the court’s determination that the 1842 account was jointly held with survivorship rights. ¶ 54 In summary, the trial court’s denial of the Estate’s motion for turnover of the funds in the 1842 account was not against the manifest weight of the evidence. - 17 - 2025 IL App (2d) 240780 ¶ 55 III.

12025–2025
Relf v. Shatayeva green
ill · 2013
1 sentence

2023If a party elects to have a special representative appointed under this paragraph (2), the recovery shall be limited to the proceeds of any liability insurance protecting the estate and shall not bar the estate from enforcing any claims that might have been available to it as counterclaims. (c) If a party commences an action against a deceased person whose death is unknown to the party before the expiration of the time limited for the commencement thereof, and the cause of action survives, and is not otherwise barred, the action may be commenced against the deceased person’s personal represent

12023–2023
In re Estate of Zivin green
illappct · 2015
1 sentence

2023Id. slip op. 3. ¶ 17 We read the federal case in sync with our ruling today.

12023–2023
Chrysler v. Darnall green
illappct · 1992
1 sentence

2023Id. at 678 . ¶ 145 Accordingly, we conclude that (1) on this record, the jury’s award of $0 for loss of society was not unreasonable or arbitrary and (2) as a result, the trial court did not abuse its discretion by denying the Estate’s motion for a new trial. ¶ 146 3.

12023–2023
Miller v. Sarah Bush Lincoln Health Center neutral
illappct · 2016
2 sentences

2023Reducing the Judgment ¶ 147 Last, the Estate argues that (1) Rossi did not “allege or prove the source or origin of the $1,422,700 they sought in reduction” and (2) the trial court erred by applying Second District precedent from Perkey, 2013 IL App (2d) 120470 , to conclude that a judgment may be reduced by the amount of medical bills that the medical providers had written-off, pursuant to section 2-1205 of the Code; instead, the Estate contends that the Fourth District case of Miller v. - 33 - Sarah Bush Lincoln Health Center, 2016 IL App (4th) 150728 , 56 N.E.3d 599 , should be applied to t

2023Reducing the Judgment ¶ 147 Last, the Estate argues that (1) Rossi did not “allege or prove the source or origin of the $1,422,700 they sought in reduction” and (2) the trial court erred by applying Second District precedent from Perkey, 2013 IL App (2d) 120470 , to conclude that a judgment may be reduced by the amount of medical bills that the medical providers had written-off, pursuant to section 2-1205 of the Code; instead, the Estate contends that the Fourth District case of Miller v. - 33 - Sarah Bush Lincoln Health Center, 2016 IL App (4th) 150728 , 56 N.E.3d 599 , should be applied to t

12023–2023
Chicago City Railway Co. v. Smith neutral
ill · 1907
2 sentences

2023Co. v. Smith, 226 Ill. 178 , 80 N.E. 716 (1907).

2023Co. v. Smith, 226 Ill. 178 , 80 N.E. 716 (1907).

12023–2023
Perkey v. Portes-Jorol green
illappct · 2014
1 sentence

2023Reducing the Judgment ¶ 147 Last, the Estate argues that (1) Rossi did not “allege or prove the source or origin of the $1,422,700 they sought in reduction” and (2) the trial court erred by applying Second District precedent from Perkey, 2013 IL App (2d) 120470 , to conclude that a judgment may be reduced by the amount of medical bills that the medical providers had written-off, pursuant to section 2-1205 of the Code; instead, the Estate contends that the Fourth District case of Miller v. - 33 - Sarah Bush Lincoln Health Center, 2016 IL App (4th) 150728 , 56 N.E.3d 599 , should be applied to t

12023–2023
Power Dry of Chicago, Inc. v. Bean green
illappct · 2022
2 sentences

2022Williams prepared an estate analysis report for the decedent, and Dooley executed a - 27 - 2022 IL App (2d) 210043 MetLife “customer profile” form that stated her investment and tax objectives.

2022Id.

12022–2022
In re Estate of Ries green
illappct · 2021
1 sentence

2021Critical here, the lawsuit was the Estate’s sole asset. ¶8 In December 2016, the Department filed against the Estate a claim for the entirety of the medical expenses it had paid on Lois’s behalf during her lifetime, i.e., $212,567.94. -2- 2021 IL App (2d) 191027 ¶9 In 2018, the Estate sought to settle the lawsuit and approached the Department about reducing its claim.

12021–2021
Schacht v. Lome green
illappct · 2016
1 sentence

2021Schacht v. Lome, 2016 IL App (1st) 141931, ¶ 34 . ¶ 16 Here, the trial court granted the Estate’s motion to dismiss pursuant to section 2-619(a)(3).

12021–2021
In re Estate of Stewart green
illappct · 2016
1 sentence

2016However, as we will explain, Harper’s later conduct, even after it was “too late” to save Stewart, may still -29- 2016 IL App (2d) 151117 be relevant to the willful-and-wanton element of the claim.

12016–2016
In Re Estate of Beider green
illappct · 1994
12003–2003
Wojdyla v. City of Park Ridge green
ill · 1992
11994–1994
Mitseff v. Acme Steel Company neutral
ilnd · 1962
11993–1993
Schloegl v. Nardi green
illappct · 1968
11990–1990
Madden v. Kuehn green
illappct · 1978
11990–1990
In Re Estate of Bajonski green
illappct · 1984
11987–1987
Newman v. Gates green
· 1907
11979–1979
Newman v. Gates green
ind · 1904
11979–1979
Balch v. English neutral
illappct · 1928
11974–1974
Brosam v. Employer's Mutual Casualty Co. green
illappct · 1965
11974–1974
Commissioner of Internal Revenue v. Netcher green
ca7 · 1944
11972–1972
In re the Estate of Brown neutral
illappct · 1917
11972–1972
In Re Estate of Kuhn green
illappct · 1967
11972–1972
Walter Wanger Pictures, Inc. v. Rogan neutral
scotus · 1944
11972–1972
Chicago Title & Trust Co. v. Corporation of the Fine Arts Building neutral
ill · 1919
11965–1965
Brown v. Brown green
ill · 1928
11955–1955
Hessick v. Hessick neutral
ill · 1897
11955–1955
Murdock v. Murdock green
ill · 1905
11955–1955
Taylor v. Taylor neutral
ill · 1893
11925–1925
Union Trust Co. v. Shoemaker green
ill · 1913
11919–1919

Statutes the citing opinions construe

IL § 735 ILCS 5/13-209 (4) IL § 735 ILCS 5/2-615 (3) IL § 735 ILCS 5/2-619 (3) IL § 755 ILCS 5/18-1 (3) IL § 755 ILCS 5/18-12 (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

PA 231 (1901–2026) IN 60 (1900–2026) IL 48 (1903–2025) TX 39 (1919–2026) NY 37 (1877–2025) OH 33 (1943–2026) CA 26 (1874–2026) FL 25 (1940–2025) WA 23 (1910–2026) MS 18 (1948–2023) GA 18 (1961–2025) KY 17 (1939–2025) WI 16 (1933–2026) MO 15 (1890–2018) IA 14 (1933–2018) KS 12 (1888–2024) MT 12 (1897–2023) AL 11 (1884–2017) MD 11 (1920–2025) CT 11 (1926–2025) SD 11 (1926–2024) NE 9 (1957–2025) TN 9 (1917–2019) OK 9 (1913–2000) CO 9 (1960–2018) NM 9 (1995–2025) ME 8 (1951–2021) AR 8 (1896–2024) AZ 8 (1996–2026) NJ 7 (1907–2026) SC 7 (1999–2023) VA 6 (1795–2020) OR 6 (1926–1987) DE 5 (2021–2026) UT 5 (1912–2023) ID 5 (1925–2025) ND 5 (1932–2025) MN 5 (1938–2012) HI 4 (1955–2026) VI 4 (1960–2015) MA 4 (1929–2003) NC 3 (1928–2015) LA 3 (1990–2007) NH 3 (2015–2017) WY 3 (1982–2010) MI 3 (2010–2018) NV 3 (1959–2017) WV 3 (2008–2024) VT 2 (1872–2018) DC 2 (2008–2021) RI 2 (1990–2000) AK 2 (1995–2023)

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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