writing requirement in Illinois

2026The supreme court disagreed, concluding that an oral finding on the record, once transcribed, may satisfy the writing requirement of section 2–27(1) “provided that it is explicit and advises the parties of the basis for the court’s decision.” Id. at 377 .

2024In my opinion, the trial court need not recite the exact reasoning twice during its oral pronouncement 6 where, as it did here, it relies on the same facts in weighing the required factors and, thereby, its ultimate decision regarding detention. ¶ 21 In In re Madison H., 215 Ill. 2d 364 (2005), our supreme court considered a similar writing requirement under section 2-27(1) of the Juvenile Court Act of 1987 (Act) (705 ILCS 405/2-27(1) (West 2002)).

2020However, this court may relax the writing requirement when “something exists in the record stating the basis for the court’s determination ***.” In re S.E., 319 Ill.

2005In other words, so long as something exists in the record stating the basis for the court’s determination, the writing requirement should he deemed satisfied, regardless of whether the ‘writing’ was prepared by the court reporter or the court’s administrative staff.” S.E., 319 Ill.

2020App. 3d 674, 684-85 , 773 N.E.2d 1259, 1267-68 (2002) (holding the trial court’s oral ruling satisfied the writing requirement contained in section 2-28 of the Juvenile Court Act because it specifically relied on DCFS reports and these reports adequately contained the basis for the court’s decision).

2005See also In re Kenneth F., 332 Ill.App.3d 674, 684-85 , 266 Ill.Dec. 189 , 773 N.E.2d 1259 (2002) (holding that the trial court's oral ruling satisfied the writing requirement contained in section 2-28 of the Act because in its oral ruling the trial court specifically relied on DCFS and CASA reports, and these reports adequately contained the basis for the court's decision).

2015The Trust argues it fully performed because Wolf found the property, negotiated its purchase and the lease thereof, contributed the “agreed amount” toward the purchase, and “helped with the collection of rent and repairs.” ¶ 44 We recognize that there is an exception to the statute of frauds’ writing requirement where one party completely performs under a contract (Anderson v. Kohler, 397 Ill.

2014The Trust argues it fully performed because Wolf found the property, negotiated its purchase and the lease thereof, contributed the “agreed amount” toward the purchase, and “helped with the collection of rent and repairs.” &44 We recognize that there is an exception to the statute of frauds’ writing requirement where one party completely performs under a contract (Anderson v. Kohler, 397 Ill.

2010Further, while the appellate court in both this case and others had concluded that recovery in contract was per se unavailable, the appellate court in Fandel v. Allen, 398 Ill.

2010Further, while the appellate court in both this case and others had concluded that recovery in contract was per se unavailable, the appellate court in Fandel v. Allen, 398 Ill.

2005In re K.S., 317 Ill.

2005In re K.S., 317 Ill.App.3d 830, 833 , 251 Ill.Dec. 344 , 740 N.E.2d 425 (2000).

2003The purpose of the writing requirement of the Frauds Act is not to enable parties “ ‘to repudiate contracts that they have in fact made; it is only to prevent the fraudulent enforcement of asserted contracts that were in fact not made.’ ” Haas v. Cravatta, 71 Ill.

2003The purpose of the writing requirement of the Frauds Act is not to enable parties "to repudiate contracts that they have in fact made; it is only to prevent the fraudulent enforcement of asserted contracts that were in fact not made.' " Haas v. Cravatta , 71 Ill.

2002In re Spak , 188 Ill. 2d 53, 67 , 719 N.E.2d 747, 754 (1999).

2002In re Spak , 188 Ill. 2d 53, 67 , 719 N.E.2d 747, 754 (1999).

2003The court decided that the other documents were "example[s] of the evidence supporting plaintiff 's allegations" ( McCormick , 118 Ill.

2003The court decided that the other documents were “example[s] of the evidence supporting plaintiffs allegations” (McCormick, 118 Ill.

2024See In re Leona W., 228 Ill. 2d 439, 458-59 (2008) (explaining that, in Madison H., the court noted “that the purpose of the writing requirement was to give the parties notice of the reasons forming the court’s decision and to preserve the reasoning for appellate review” and “concluded that those purposes would be 10 No. 1-23-2503B served just as well by explicit oral findings stated during the hearing and then transcribed and made part of the record. [Citation.] Accordingly, we concluded that where an oral pronouncement is explicit and sufficient to advise the parties of the court’s reasoning

2024See In re Leona W., 228 Ill. 2d 439, 458-59 (2008) (explaining that, in Madison H., the court noted “that the purpose of the writing requirement was to give the parties notice of the reasons forming the court’s decision and to preserve the reasoning for appellate review” and “concluded that those purposes would be 10 No. 1-23-2503B served just as well by explicit oral findings stated during the hearing and then transcribed and made part of the record. [Citation.] Accordingly, we concluded that where an oral pronouncement is explicit and sufficient to advise the parties of the court’s reasoning

2024When our supreme court held that oral findings of fact were sufficient to satisfy the writing requirement of section 2-27(1) of the Juvenile Court Act (705 ILCS 405/2-27(1) (West 2002)), the court found that oral findings, “to the extent that they are explicit and advise the parties of the basis for the court’s decision, satisfy the purpose of the writing requirement, which is to ‘give the parties notice of the reasons forming the basis for the removal of the child and to preserve this reasoning for appellate review.’ ” (Emphasis added.) In re B’Yata I., 2013 IL App (2d) 130558, ¶ 31 (quoting

2021See In re R.M.S., 187 Ill.

2019Under subsections 450/30.1(2)(i)-(ii) of the Act, if a licensed accountant “identifies in writing to the client those persons who are intended to rely on the services,” and “sends a copy of such writing or similar statement to those persons identified in the writing or statement,” then the accountant “may be held liable only to such persons intended to so rely, in addition to those persons in privity of contract.” Id. ¶ 30 We find the Salta auditing contract precludes liability as the Mayer defendants satisfied the writing requirement of subsections 450/30.1(2)(i) and (ii) of the Act.

2019See id.

1995See Lam v. Northern Illinois Gas Co. (1983), 114 Ill.

1983See Easley v. Apollo Detective Agency, Inc. (1979), 69 Ill.