gross error (Illinois) · Go Syfert
← Illinois issues

gross error in Illinois

46 Illinois opinions name it 2 courts 1942–2025 3 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 (12)

CaseFollowedCited
Edward Electric Co. v. Automation, Inc.green
illappct · 1992 · cited in 5 Illinois opinions naming this issue, 2004–2011
2 sentences

2011Illinois case law has also established that an award may be vacated “if it results in the contravention of a paramount consideration of public policy [citation], where a gross error of law or fact appears on the face of the award [citation], or where the award fails to dispose of all matters properly submitted to the arbitrators [citation].” Edward Electric Co. v. Automation, Inc., 229 Ill.

2006“Case law has established that in addition to the grounds stated above, an arbitration award may be vacated if it results in the contravention of a paramount consideration of public policy [citation], where a gross error of law or fact appears on the face of the award [citation], or where the award fails to dispose of all matters properly submitted to the arbitrators.” Edward Electric, 229 Ill.

45
Galasso v. KNS Companies, Inc.green
illappct · 2006 · cited in 7 Illinois opinions naming this issue, 2007–2025
2 sentences

2011However, an award may be vacated where “a gross error of law or fact appears on the award’s face.” (Emphasis in orginal.) Id.; see Galasso, 364 Ill.

2009App. 3d at 130 , 845 N.E.2d at 862 . “[A] court may only vacate an arbitration award where a gross error of law or fact appears on the award’s face.” Beatty, 374 Ill.

37
TruServ Corp. v. Ernst & Young LLPgreen
illappct · 2007 · cited in 2 Illinois opinions naming this issue, 2008–2008
2 sentences

2008TruServ Corp. v. Ernst & Young LLP, 376 Ill.

2008TruServ Corp. v. Ernst & Young LLP, 376 Ill.

22
ABC Trans National Transport, Inc. v. Aeronautics Forwarders, Inc.green
illappct · 1980 · cited in 2 Illinois opinions naming this issue, 1999–1999
2 sentences

1999See ABC Trans National Transport, Inc. v. Aeronautics Forwarders, Inc., 90 Ill.

1999See ABC Trans National Transport, Inc. v. Aeronautics Forwarders, Inc. , 90 Ill.

22
Herricane Graphics, Inc. v. Blinderman Construction Co.green
illappct · 2004 · cited in 6 Illinois opinions naming this issue, 2005–2024
2 sentences

2009“To vacate an award based on a gross error of law, a reviewing court must be able to conclude, from the award’s face, that the arbitrator was so mistaken as to the law that, if apprised of the mistake, he would have acted differently.” Herricane, 354 Ill.

2005As this court has explained: “Although a court cannot vacate an award due to errors in judgment or mistakes of fact or law, a court can vacate an arbitration award where a gross error of law or fact appears on the award’s face or where the award fails to dispose of all matters properly submitted to the arbitrator. [Citation.] To vacate an award based on a gross error of law, a reviewing court must be able to conclude, from the award’s face, that the arbitrator was so mistaken as to the law that, if apprised of the mistake, he would have ruled differently. [Citation.] The burden is placed on th

16
Anderson v. Golf Mill Ford, Inc.green
illappct · 2008 · cited in 2 Illinois opinions naming this issue, 2009–2011
2 sentences

2011Ray disputes all of -5- these contentions, as shall be developed below. ¶ 24 In considering Clanton’s contentions, we are mindful that, unlike review of a lower court’s decision, judicial review of an arbitration award is “extremely limited.” Anderson v. Golf Mill Ford, Inc., 383 Ill.

2009Nonetheless, a court may vacate an award if “a gross error of law or fact appears on the face of the award.” Anderson, 383 Ill.

12
First Merit Realty Services Inc. v. Amberly Square Apartments, L.P.green
illappct · 2007 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025See First Merit -16- 1-24-1162 Realty Services, Inc. v. Amberly Square Apartments, L.P., 373 Ill.

11
Griggsville-Perry Community Unit School District No. 4 v. Illinois Educational Labor Relations Boardgreen
ill · 2013 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025See Griggsville-Perry, 2013 IL 113721, ¶ 20 . ¶ 52 First, Arbitrator Clauss has made a gross error of judgment on the face of the award by ignoring the term “paid time off” in the facility closure provisions of the CBAs.

11
Bruzas v. Richardsongreen
illappct · 2011 · cited in 1 Illinois opinions naming this issue, 2020–2020
2 sentences

2020See Bruzas, 408 Ill.

2020In the absence of a gross error of law or fact apparent from the face of the award, the circuit court did not err in confirming the award and granting summary judgment in favor of Schiff. ¶ 21 Berger next argues that we should reverse the circuit court’s summary judgment order in favor of Schiff, and vacate the arbitration award, because the arbitrator violated section 5(b) and section 12(a)(4) of the Uniform Arbitration Act when it denied his motion to compel discovery. ¶ 22 Section 5(b) states: “The parties are entitled to be heard, to present evidence material to the controversy and to cros

11
Law Offices of Nye & Associates v. Boadogreen
illappct · 2012 · cited in 1 Illinois opinions naming this issue, 2012–2012
1 sentence

2012See Law Offices of Nye & Associates, Ltd. v. Boado, 2012 IL App (2d) 110804, ¶ 23 (citing Foutch v. O’Bryant, 99 Ill. 2d 389, 391-92 (1984)). -6- plaintiff’s conduct was a gross violation of supreme court rules because he never disclosed the witness and did not even mention the witness during his deposition.

11
Foutch v. O'BRYANTgreen
ill · 1984 · cited in 1 Illinois opinions naming this issue, 2012–2012
1 sentence

2012See Law Offices of Nye & Associates, Ltd. v. Boado, 2012 IL App (2d) 110804, ¶ 23 (citing Foutch v. O’Bryant, 99 Ill. 2d 389, 391-92 (1984)). -6- plaintiff’s conduct was a gross violation of supreme court rules because he never disclosed the witness and did not even mention the witness during his deposition.

11
In Re Woldmangreen
ill · 1983 · cited in 1 Illinois opinions naming this issue, 1986–1986
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 (40)

CaseCitedYears
In Re Stillo green
ill · 1977
2 sentences

2004This court concluded that conversion of client funds to one’s own use is “an act involving moral turpitude, and, in the absence of mitigating circumstances, *** is a gross violation of the attorney’s oath, calling for the attorney’s disbarment.” Stillo, 68 Ill. 2d at 54 .

2004This court concluded that conversion of client funds to one’s own use is “an act involving moral turpitude, and, in the absence of mitigating circumstances, *** is a gross violation of the attorney’s oath, calling for the attorney’s disbarment.” Stillo , 68 Ill. 2d at 54 .

81979–2004
In Re Ahern neutral
ill · 1962
2 sentences

1982(See, e.g., In re Fumo (1972), 52 Ill. 2d 307 ; In re Snitoff (1972), 53 Ill. 2d 50 ; In re Lingle (1963), 27 Ill. 2d 459 ; In re Patlak (1938), 368 Ill. 547 .) As this court stated in In re Stillo (1977), 68 Ill. 2d 49 , 54: “When a lawyer *** converts a client’s funds to his own personal use he commits an act involving moral turpitude, and, in the absence of mitigating circumstances, such conversion is a gross violation of the attorney’s oath, calling for the attorney’s disbarment.” (In re Royal (1963), 29 Ill. 2d 458, 464 ; In re Ahern (1962), 26 Ill. 2d 104, 110 .) Any mitigating factors u

1982(See, e.g., In re Fumo (1972), 52 Ill.2d 307 ; In re Snitoff (1972), 53 Ill.2d 50 ; In re Lingle (1963), 27 Ill.2d 459 ; In re Patlak (1938), 368 Ill. 547 .) As this court stated in In re Stillo (1977), 68 Ill.2d 49 , 54: "When a lawyer * * * converts a client's funds to his own personal use he commits an act involving moral turpitude, and, in the absence of mitigating circumstances, such conversion is a gross violation of the attorney's oath, calling for the attorney's disbarment." ( In re Royal (1963), 29 Ill.2d 458, 464 ; In re Ahern (1962), 26 Ill.2d 104, 110 .) Any mitigating factors urge

41977–1982
In Re Royal green
ill · 1963
2 sentences

1982(See, e.g., In re Fumo (1972), 52 Ill. 2d 307 ; In re Snitoff (1972), 53 Ill. 2d 50 ; In re Lingle (1963), 27 Ill. 2d 459 ; In re Patlak (1938), 368 Ill. 547 .) As this court stated in In re Stillo (1977), 68 Ill. 2d 49 , 54: “When a lawyer *** converts a client’s funds to his own personal use he commits an act involving moral turpitude, and, in the absence of mitigating circumstances, such conversion is a gross violation of the attorney’s oath, calling for the attorney’s disbarment.” (In re Royal (1963), 29 Ill. 2d 458, 464 ; In re Ahern (1962), 26 Ill. 2d 104, 110 .) Any mitigating factors u

1982(See, e.g., In re Fumo (1972), 52 Ill.2d 307 ; In re Snitoff (1972), 53 Ill.2d 50 ; In re Lingle (1963), 27 Ill.2d 459 ; In re Patlak (1938), 368 Ill. 547 .) As this court stated in In re Stillo (1977), 68 Ill.2d 49 , 54: "When a lawyer * * * converts a client's funds to his own personal use he commits an act involving moral turpitude, and, in the absence of mitigating circumstances, such conversion is a gross violation of the attorney's oath, calling for the attorney's disbarment." ( In re Royal (1963), 29 Ill.2d 458, 464 ; In re Ahern (1962), 26 Ill.2d 104, 110 .) Any mitigating factors urge

41977–1982
Rauh v. Rockford Products Corp. green
ill · 1991
2 sentences

1992Stat. 1989, ch. 10, par. 112(a).) Case law has established that in addition to the grounds stated above, an arbitration award may be vacated if it results in the contravention of a paramount consideration of public policy (American Federation of State, County & Municipal Employees v. State of Illinois (1988), 124 Ill. 2d 246, 260 , 529 N.E.2d 534 ), where a gross error of law or fact appears on the face of the award (Rauh v. Rockford Products Corp. (1991), 143 Ill. 2d 377, 393 , 574 N.E.2d 636 ), or where the award fails to dispose of all matters properly submitted to the arbitrators (Harris v

1992Stat. 1989, ch. 10, par. 112(a).) Case law has established that in addition to the grounds stated above, an arbitration award may be vacated if it results in the contravention of a paramount consideration of public policy (American Federation of State, County & Municipal Employees v. State of Illinois (1988), 124 Ill. 2d 246, 260 , 529 N.E.2d 534 ), where a gross error of law or fact appears on the face of the award (Rauh v. Rockford Products Corp. (1991), 143 Ill. 2d 377, 393 , 574 N.E.2d 636 ), or where the award fails to dispose of all matters properly submitted to the arbitrators (Harris v

31992–1999
Board of Education v. Chicago Teachers Union, Local No. 1 green
ill · 1981
2 sentences

2011Chicago Teachers Union, 86 Ill. 2d at 477 .

1995Board of Education v. Chicago Teachers Union, Local No. 1 (1981), 86 Ill. 2d 469, 477 , 427 N.E.2d 1199, 1202 .

21995–2011
Garver v. Ferguson green
ill · 1979
2 sentences

2010A panel exceeds its authority when “ ‘all fair and reasonable minds would agree that the construction of the contract made by the arbitrator was not possible under a fair interpretation of the contract.’ ” Garver v. Ferguson, 76 Ill. 2d 1, 9-10 , 389 N.E.2d 1181 (1979), quoting M.

2010A panel exceeds its authority when “ ‘all fair and reasonable minds would agree that the construction of the contract made by the arbitrator was not possible under a fair interpretation of the contract.’ ” Garver v. Ferguson, 76 Ill. 2d 1, 9-10 , 389 N.E.2d 1181 (1979), quoting M.

22010–2010
Martin v. State Farm Mutual Automobile Insurance green
illappct · 2004
2 sentences

2007The Doctors' Company argues that this is gross error, and it points to Martin v. State Farm Mutual Automobile Insurance Co., 348 Ill.

2007The Doctors’ Company argues that this is gross error, and it points to Martin v. State Farm Mutual Automobile Insurance Co., 348 Ill.

22007–2007
American Service Insurance v. Passarelli green
illappct · 2001
2 sentences

2007The Doctors' Company points to the appellate court's pronouncement in American Service Insurance Co. v. Passarelli, 323 Ill.

2007The Doctors’ Company points to the appellate court’s pronouncement in American Service Insurance Co. v. Passarelli, 323 Ill.

22007–2007
In Re Feldman green
ill · 1982
2 sentences

2004Later, in In re Feldman, 89 Ill. 2d 7 (1982), this court ordered disbarment of an attorney who converted client funds and then compounded his wrongdoing by signing another client’s name on checks to obtain funds so that he could cover up the earlier conversion.

2004Later, in In re Feldman , 89 Ill. 2d 7 (1982), this court ordered disbarment of an attorney who converted client funds and then compounded his wrongdoing by signing another client’s name on checks to obtain funds so that he could cover up the earlier conversion.

22004–2004
Lemna v. Harry F. Shea & Co. green
illappct · 1993
2 sentences

2001App. 3d 916 , 628 N.E.2d 577 (1993) (defendant’s disagreement with arbitrator’s interpretation of the evidence does not constitute a gross error of law or facts).

2001App. 3d 916 , 628 N.E.2d 577 (1993) (defendant's disagreement with arbitrator's interpretation of the evidence does not constitute a gross error of law or facts).

22001–2001
Perkins Restaurants Operating Co. v. Van Den Bergh Foods Co. green
illappct · 1995
2 sentences

2001Perkins Restaurants Operating Co. v. Van Den Bergh Foods Co., 276 Ill.

2001Perkins Restaurants Operating Co. v. Van Den Bergh Foods , 276 Ill.

22001–2001
Thomas v. Leyva green
illappct · 1995
2 sentences

1999App. 3d 678 , 584 N.E.2d 317 (1991)), or when a gross error of law or fact appears on the face of the award (Thomas v. Leyva, 276 Ill.

1999App. 3d 678 , 584 N.E.2d 317 (1991)), or when a gross error of law or fact appears on the face of the award ( Thomas v. Leyva , 276 Ill.

21999–1999
Department of Central Management Services v. American Federation of State, County & Municipal Employee green
illappct · 1991
2 sentences

1999App. 3d 678 , 584 N.E.2d 317 (1991)), or when a gross error of law or fact appears on the face of the award (Thomas v. Leyva, 276 Ill.

1999App. 3d 678 , 584 N.E.2d 317 (1991)), or when a gross error of law or fact appears on the face of the award ( Thomas v. Leyva , 276 Ill.

21999–1999
In Re Agin neutral
ill · 1970
2 sentences

1979(In re Agin [1970], 45 Ill. 2d 126, 131 .) When a lawyer, further, converts a client’s funds to his own personal use he commits an act involving moral turpitude, and, in the absence of mitigating circumstances, such conversion is a gross violation of the attorney’s oath, calling for the attorney’s disbarment.

1977(In re Agin, 45 Ill. 2d 126, 131 .) When a lawyer, further, converts a client’s funds to his own personal use he commits an act involving moral turpitude, and, in the absence of mitigating circumstances, such conversion is a gross violation of the attorney’s oath, calling for the attorney’s disbarment.

21977–1979
People v. Kyles green
illappct · 2020
1 sentence

2020Indeed, giving the admonishment then would have been a gross error: it was too late to file a motion to vacate the judgment and withdraw the guilty plea. -9- 2020 IL App (2d) 180087 ¶ 27 Defendant’s third and fourth claims of error relate to the proceedings following his pro se motion.

12020–2020
Clanton v. Ray green
illappct · 2011
2 sentences

2020Id.

2020“A gross error of law exists only where it appears from the face of the award that the arbitrator was so mistaken as to the law that, if the arbitrator had been informed of the mistake, the award would have been different.” Id. ¶ 20 No gross error of law appears on the face of the arbitration award as to the breach of oral contract claim, as the arbitrator correctly cited case law holding that for an oral contract to be -7- No. 1-19-2329 binding, the material terms of the agreement must be definite enough to determine the parties’ intent.

12020–2020
Beatty v. Doctors' Co. green
illappct · 2007
2 sentences

2009App. 3d at 130 , 845 N.E.2d at 862 . “[A] court may only vacate an arbitration award where a gross error of law or fact appears on the award’s face.” Beatty, 374 Ill.

2009App. 3d at 563 , 871 N.E.2d at 142 , citing Galasso, 364 Ill.

12009–2009
Yorulmazoglu v. Lake Forest Hospital green
illappct · 2005
1 sentence

2007Yorulmazoglu, 359 Ill.

12007–2007
Hetherington v. Continental Insurance Co. of New York green
illappct · 1941
11996–1996
Smith ex rel. Inter-Ocean Casualty Co. v. Allemannia Fire Insurance green
illappct · 1920
1 sentence

1996To quote Smith , an appraisal of $111,900 for a building purchased a week earlier for a fair-market value of $21,000 and having no special value to the insured is "absurd." Smith, 219 Ill.App. at 511 .

11996–1996
Hayes v. Ennis green
illappct · 1996
11996–1996
Harris v. Allied American Insurance green
illappct · 1987
11992–1992
American Federation of State, County & Municipal Employees v. State green
ill · 1988
11992–1992
In Re Braner green
ill · 1987
11990–1990
In Re Smith green
ill · 1979
11986–1986
In Re Patlak neutral
ill · 1938
11982–1982
In Re Smith green
ill · 1976
11982–1982
In Re Snitoff green
ill · 1972
11982–1982
In Re Fumo green
ill · 1972
11982–1982
In Re Lingle green
ill · 1963
11982–1982
In re Patt neutral
ill · 1980
11982–1982
In Re Andros green
ill · 1976
11980–1980
In re Fumo green
ill · 1961
11979–1979
Country Mut. Ins. Co. v. Nat. Bank of Decatur green
illappct · 1969
11977–1977
White Star Mining Co. v. Hultberg green
ill · 1906
11977–1977
Betrand Appeal green
pa · 1973
11974–1974
State v. Newell green
mo · 1971
11974–1974
United States v. Robert H. Kilgen, Jr., and Gary Lee Ansley green
ca5 · 1970
11974–1974
United States v. Robert H. Kilgen, Jr. green
ca5 · 1971
11974–1974
In re Hanson neutral
kan · 1910
11942–1942

Statutes the citing opinions construe

IL § 710 ILCS 5/12 (21) IL § 710 ILCS 5/1 (10) IL § 710 ILCS 5/13 (7) IL § 710 ILCS 5/2 (7) IL § 820 ILCS 115/1 (6) IL § 710 ILCS 5/10 (5) IL § 215 ILCS 5/155 (4) IL § 705 ILCS 225/0.01 (4) IL § 815 ILCS 505/10a (4) USC § 31u.s.c.3729 (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

CA 53 (1913–2026) IL 46 (1942–2025) NJ 32 (1937–2025) TX 22 (1867–2019) PA 18 (1923–2024) NY 17 (1874–2016) IN 14 (1874–2025) MI 14 (1863–2023) OH 14 (1908–2023) AK 11 (1978–2026) AL 10 (1923–2023) NC 10 (2006–2025) MD 8 (1908–2011) MN 5 (1897–1998) CO 5 (1896–2019) NE 4 (1995–2016) SD 4 (1980–2016) OR 4 (1974–2024) MT 4 (1896–2011) WI 4 (1938–2020) MO 3 (1879–2025) WY 3 (1988–2021) MA 3 (1960–2009) FL 3 (1939–2002) AZ 3 (1916–2013) VA 2 (1979–2019) WV 2 (1931–2009) TN 2 (1992–2020) DE 2 (1978–2005) CT 2 (1956–1997) AR 2 (1995–1997) LA 2 (1918–2023) ME 2 (1892–1970) ND 2 (1901–1983)

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.

← Caselaw search · G Cite Topics · Brief Check