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Illinois Compiled Statutes

735 ILCS 5/2-1108 (2026)

Verdict - Special interrogatories

✓ current as of May 2026
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(735 ILCS 5/2-1108) (from Ch. 110, par. 2-1108)
    Sec. 2-1108. Verdict - Special interrogatories. Unless the nature of the case requires otherwise, the jury shall render a general verdict. Within the discretion of the court, the jury may be asked to find specially upon any material question or questions of fact submitted to the jury in writing. Any party may request special interrogatories. Special interrogatories shall be tendered, objected to, ruled upon and submitted to the jury as in the case of instructions. Submitting or refusing to submit a question of fact to the jury may be reviewed on appeal to determine whether the trial court abused its discretion. When any special finding of fact is inconsistent with the general verdict, the court shall direct the jury to further consider its answers and verdict. If, in the discretion of the trial court, the jury is unable to render a general verdict consistent with any special finding, the trial court shall order a new trial. During closing arguments, the parties shall be allowed to explain to the jury what may result if the general verdict is inconsistent with any special finding.
    This amendatory Act of the 101st General Assembly applies only to trials commencing on or after January 1, 2020.
(Source: P.A. 101-184, eff. 8-2-19.)

    
Notes of Decisions
Cited in 78 cases (16 in the last 5 years), 1993–2026 · leading case: Givens v. City of Chicago, 2023 IL 127837 (Ill. 2023).
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Givens v. City of Chicago, 2023 IL 127837 (Ill. 2023). · cites it 6× “Submitting or refusing to submit a question of fact to the jury may be reviewed on appeal, as a ruling on a question of law.”
Cotton v. Coccaro, 2023 IL App (1st) 220788 (Ill. App. Ct. 2023). · cites it 2× “) 735 ILCS 5/2-1108 (West 2020). - 10 - No.”
Snyder v. Curran Twp., 666 N.E.2d 818 (Ill. App. Ct. 1996). · cites it 3× “Special interrogatories shall be tendered, objected to, ruled upon and submitted to the jury as in the case of instructions. Submitting or refusing to submit a question of fact to the jury may be reviewed on appeal, as a ruling on a question of law.”
Douglas v. Arlington Park Racecourse, LLC, 2018 IL App (1st) 162962 (Ill. App. Ct. 2018). · cites it 3× “3d 824 ; 735 ILCS 5/2-1108 (West 2016) ("Submitting or refusing to submit a question of fact to the jury may be reviewed on appeal, as a ruling on a question of law.”
Stanphill v. Ortberg, 2017 IL App (2d) 161086 (Ill. App. Ct. 2017). · cites it 2× “The jury may be required by the court, and must be required on request of any party, to find specially upon any material question or questions of *936 fact submitted to the jury in writing.”
Jacobs v. Yellow Cab Affiliation, Inc., 2017 IL App (1st) 151107 (Ill. App. Ct. 2017). “Submitting or refusing to submit a question of fact to the jury may be reviewed on - 33 - appeal, as a ruling on a question of a law.”
Garcia v. Seneca Nursing Home, 2011 IL App (1st) 103085 (Ill. App. Ct. 2011). · cites it 2× “See 735 ILCS 5/2-1108 (2010). ¶ 36 Special interrogatories are designed to be the “guardian of the integrity of a general verdict in a civil jury trial [citation],” and they “test[ ] the general verdict against the jury’s determination as to one or more specific issues of…”
Bachman v. Gen. Motors Corp., 776 N.E.2d 262 (Ill. App. Ct. 2002). “Submitting or refusing to submit a question of fact to the jury may be reviewed on appeal, as a ruling on a question of law.”
Douglas v. Arlington Park Racecourse, LLC, 2018 IL App (1st) 162962 (Ill. App. Ct. 2019). · cites it 3× “City of Chicago, 2013 IL App (1st) 120901 , ¶ 32; Abruzzo, 2013 IL App (1st) 122360, ¶ 58 ; 735 ILCS 5/2-1108 (West 2016) (“Submitting or refusing to submit a question of fact to the jury may be reviewed on appeal, as a ruling on a question of law.”
Kulhanek v. Casper, 2023 IL App (1st) 221454 (Ill. App. Ct. 2023). · cites it 2× “¶ 24 Special interrogatories test the general verdict against the jury’s findings on one or more ultimate issues of fact.”
Simmons v. Garces, 745 N.E.2d 569 (Ill. App. Ct. 2001). · cites it 2× “735 ILCS 5/2-1108 (West 1998). Plaintiffs contend on appeal the court erred in entering judgment on the special interrogatory.”
Inman v. Howe Freightways, Inc., 2019 IL App (1st) 172459 (Ill. App. Ct. 2019). “735 ILCS 5/2-1108 (West 2016) ; Northern Trust Co.”
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