Illinois Compiled Statutes
735 ILCS 5/2-1102 (2026)
Examination of adverse party or agent
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(735 ILCS 5/2-1102)
(from Ch. 110, par. 2-1102)
Sec. 2-1102.
Examination of adverse party or agent.
Upon the trial of any case any party thereto or any person for whose
immediate benefit the action is prosecuted or defended, or the officers,
directors, managing agents or foreman of any party to the action, may be
called and examined as if under cross-examination at the instance of any
adverse party. The party calling for the examination is not concluded
thereby but may rebut the testimony thus given by countertestimony and
may impeach the witness by proof of prior inconsistent statements.
(Source: P.A. 82-280.)
Notes of Decisions
Cited in 28
cases (4 in the last 5 years), 1993–2025 · leading case: Leonardi v. Loyola Univ. of Chicago, 658 N.E.2d 450 (Ill. 1995).
Leonardi v. Loyola Univ. of Chicago, 658 N.E.2d 450 (Ill. 1995). “(See 735 ILCS 5/2-1102 (West 1994).) He testified as follows.”
In Re Marriage of Breitenfeldt, 840 N.E.2d 694 (Ill. App. Ct. 2005). “Respondent testified as an adverse witness (see 735 ILCS 5/2-1102 (West 2004)). He acknowledged petitioner's exhibit No.”
People v. Santiago, 949 N.E.2d 290 (Ill. App. Ct. 2011). “Under existing case law, no error occurred in the admission of the videotaped statements and the statements at the guilty plea hearings of the two codefendants. Even if the circuit court may be persuaded to limit the number of prior inconsistent statements in the course of…”
Lisowski v. Macneal Mem'l Hosp. Ass'n, 885 N.E.2d 1120 (Ill. App. Ct. 2008). “Plaintiff called Brofman in her case in chief as an adverse witness under section 2-1102 of the Code of Civil Procedure (Code) (735 ILCS 5/2-1102 (West 2006)). Brofman denied deviating from the standard of care either in performing the thoracentesis or in obtaining consent.”
McMath v. Katholi, 711 N.E.2d 1135 (Ill. App. Ct. 1999). “When defendant calls plaintiff as an adverse witness at trial (735 ILCS 5/2-1102 (West 1996)), plaintiff may now object that the questioning asks for opinion testimony ( e.”
Arians v. Larkin Bank, 625 N.E.2d 1101 (Ill. App. Ct. 1993). “The Code of Civil Procedure permits a witness to be called as an adverse party and thus be examined by leading questions as if on cross-examination, if that witness is a party to the action or is “any person for whose immediate benefit the action is prosecuted or defended, or…”
Cimino v. Sublette, 2015 IL App (1st) 133373 (Ill. App. Ct. 2015). “Sublette, as an adverse witness pursuant to section 2- 1102 of the Illinois Code of Civil Procedure (Code) (735 ILCS 5/2-1102 (West 2012)). Dr. Sublette first testified that he is a board-certified physician in internal medicine and gastroenterology (i.”
Cimino v. Sublette, 2015 IL App (1st) 133373 (Ill. App. Ct. 2015). “Sublette, as an adverse witness pursuant to section 2-1102 of the Illinois Code of Civil Procedure (Code) (735 ILCS 5/2-1102 (West 2012)). Dr. Sublette first testified that he is a board-certified physician in internal medicine and gastroenterology (i.”
Moushon v. AAA Amusement, Inc., 641 N.E.2d 1201 (Ill. App. Ct. 1994). “Linda Frank and Chuck Frank both testified as adverse witnesses under section 2-1102 of the Civil Practice Law (735 ILCS 5/2-1102 (West 1992)). Linda testified that she was the owner of Linda's Place, and her husband, Chuck, was the owner of AAA.”
In re Marriage of Fanady, 2022 IL App (1st) 201100-U (Ill. App. Ct. 2022). “Steve next maintains that the court erred in allowing Gina to call him as an adverse witness pursuant to section 2-1102 of the Code of Civil Procedure (Code) (735 ILCS 5/2-1102 (West 2018)) where the court had previously entered an order barring Gina from calling any witnesses…”
Frances House, Inc. v. The Illinois Dep't of Pub. Health, 2015 IL App (1st) 140750 (Ill. App. Ct. 2015). “” ¶ 15 Kanthak also called Montgomery as a witness “as if under cross examination pursuant to §2-1102 of the Illinois Code of Civil Procedure (735 ILCS 5/2-1102 [(West __)].” She testified that “she was the only Department representative conducting the survey” of Kanthak.”
Frances House, Inc. v. Illinois Dep't of Pub. Health, 2015 IL App (1st) 140750 (Ill. App. Ct. 2015). “” ¶ 15 Kanthak also called Montgomery as a witness “as if under cross examination pursuant to §2-1102 of the Illinois Code of Civil Procedure (735 ILCS 5/2-1102).” She testified that “she was the only Department representative conducting the survey” of Kanthak.”
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