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Illinois Compiled Statutes

735 ILCS 5/2-1201 (2026)

Return of verdict - Separate counts - Defective or unproved counts

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(735 ILCS 5/2-1201) (from Ch. 110, par. 2-1201)
    Sec. 2-1201. Return of verdict - Separate counts - Defective or unproved counts. (a) It is sufficient for the jury to pronounce its verdict by its foreman in open court, without reducing it to writing, if it is a general verdict. The clerk shall enter it in form, under the direction of the court.
    (b) Promptly upon the return of a verdict, the court shall enter judgment thereon.
    (c) If there are several counts in a complaint, counterclaim or third-party complaint based on different claims upon which separate recoveries might be had, the court shall, on the motion of any party, direct the jury to find a separate verdict upon each claim.
    (d) If several grounds of recovery are pleaded in support of the same claim, whether in the same or different counts, an entire verdict rendered for that claim shall not be set aside or reversed for the reason that any ground is defective, if one or more of the grounds is sufficient to sustain the verdict; nor shall the verdict be set aside or reversed for the reason that the evidence in support of any ground is insufficient to sustain a recovery thereon, unless before the case was submitted to the jury a motion was made to withdraw that ground from the jury on account of insufficient evidence and it appears that the denial of the motion was prejudicial.
(Source: P.A. 83-707.)

    
Notes of Decisions
Cited in 31 cases (6 in the last 5 years), 1995–2025 · leading case: Dillon v. Evanston Hosp., 771 N.E.2d 357 (Ill. 2002).
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Dillon v. Evanston Hosp., 771 N.E.2d 357 (Ill. 2002). · cites it 2× “" 735 ILCS 5/2-1201(d) (West 2000). Because Dr.”
Luther v. Norfolk & W. Ry. Co., 649 N.E.2d 1000 (Ill. App. Ct. 1995). · cites it 3× “Under section 2-1201(d) of the Civil Practice Law (735 ILCS 5/2-1201(d) (West 1992)), a general verdict can be sustained on any of several bases of liability and will not be reversed due to the impairment of one of the theories.”
Inman v. Howe Freightways, Inc., 2019 IL App (1st) 172459 (Ill. App. Ct. 2019). “" To this end, plaintiff argues that, assuming arguendo that the sanctions were improper, because Howe did not submit special interrogatories to the jury to ascertain which of the six theories of negligence against it formed the basis of the jury's verdict, we cannot determine…”
Allen v. Sarah Bush Lincoln Health Ctr., 2021 IL App (4th) 200360 (Ill. App. Ct. 2021). “” 735 ILCS 5/2-1201(d) (West 2018). ¶ 120 “When there is a general verdict and more than one theory is presented, the verdict will be upheld if there was sufficient evidence to sustain either theory, and the [moving party], having failed to request special interrogatories,…”
Arient v. Alhaj-Hussein, 2017 IL App (1st) 162369 (Ill. App. Ct. 2017). · cites it 3× “" 735 ILCS 5/2-1201(d) (West 2012). ¶ 45 In this case, the jury returned a general verdict, and because the defendants did not submit special interrogatories, we have no way of knowing upon which of the acts of negligence alleged against Dr.”
Wilcox v. Advocate Condell Med. Ctr., 2024 IL App (1st) 230355 (Ill. App. Ct. 2024). “” 735 ILCS 5/2-1201(d) (West 2022). This case involved a claim for damages from Advocate arising out of a single loss, the wrongful death of Scott Wilcox, which the plaintiff pursued through two grounds of recovery.”
McQueen v. Green, 2020 IL App (1st) 190202 (Ill. App. Ct. 2020). · cites it 2× “¶ 73 Section 2-1201(d) of the Code of Civil Procedure provides that, “[i]f several grounds of recovery are pleaded in support of the same claim, whether in the same or different counts, an entire verdict rendered for that claim shall not be set aside or reversed for the reason…”
McQueen v. Green, 2020 IL App (1st) 190202 (Ill. App. Ct. 2020). · cites it 2× “¶ 73 Section 2-1201(d) of the Code of Civil Procedure provides that, “[i]f several grounds of recovery are pleaded in support of the same claim, whether in the same or different counts, an entire verdict rendered for that claim shall not be set aside or reversed for the reason…”
Kennedy v. Com. Carriers, Inc., 689 N.E.2d 293 (Ill. App. Ct. 1997). · cites it 4× “Section 2-1201 of the Code of Civil Procedure (735 ILCS 5/2-1201 (West 1992)), which provides for separate verdict forms, does not purport to interface with the class action provisions and Sections 2-801 et seq of the Code (735 ILCS 5/2-801 et seq .”
Perez v. St. Alexius Med. Ctr., 2022 IL App (1st) 181887 (Ill. App. Ct. 2022). “(citing 735 ILCS 5/2-1201(d) (West 2016)). That conclusion is not changed by the fact that the supreme court in Steed applied the general verdict rule and found “the determination of these errors is not essential to our disposition” but also found “[i]n addition” that the…”
Studt v. Sherman Health Sys., 951 N.E.2d 1131 (Ill. 2011). “The reason this is problematic for Sherman Hospital is that our Code of Civil Procedure expressly provides that where, as here, multiple grounds of recovery "are pleaded in support of the same claim, whether in the same or different counts, an entire verdict rendered for that…”
Arient v. Alhaj-Hussein, 2017 IL App (1st) 162369 (Ill. App. Ct. 2018). · cites it 2× “See 735 ILCS 5/2-1201(d) (West 2012). Because neither section 2-1201(d)’s plain text nor - 14 - decisions of our supreme court—Witherell included—justify applying that rule under the facts of this case, I respectfully dissent.”
Show all 31 citing cases →
— 735 ILCS 5/2-1201(b) — 4 cases
Hamilton v. Hastings, 2014 IL App (4th) 131021 (Ill. App. Ct. 2014).
Hamilton v. Hastings, 2014 IL App (4th) 131021 (Ill. App. Ct. 2014).
Burkhamer v. Krumske, 2015 IL App (1st) 131863 (Ill. App. Ct. 2015).
Burkhamer v. Krumske, 2015 IL App (1st) 131863 (Ill. App. Ct. 2015).
— 735 ILCS 5/2-1201(c) — 1 case
Kennedy v. Com. Carriers, Inc., 689 N.E.2d 293 (Ill. App. Ct. 1997). “Section 2-1201 of the Code of Civil Procedure (735 ILCS 5/2-1201 (West 1992)), which provides for separate verdict forms, does not purport to interface with the class action provisions and Sections 2-801 et seq of the Code (735 ILCS 5/2-801 et seq .”
— 735 ILCS 5/2-1201(d) — 26 cases
Dillon v. Evanston Hosp., 771 N.E.2d 357 (Ill. 2002). “" 735 ILCS 5/2-1201(d) (West 2000). Because Dr.”
Luther v. Norfolk & W. Ry. Co., 649 N.E.2d 1000 (Ill. App. Ct. 1995). “Under section 2-1201(d) of the Civil Practice Law (735 ILCS 5/2-1201(d) (West 1992)), a general verdict can be sustained on any of several bases of liability and will not be reversed due to the impairment of one of the theories.”
Inman v. Howe Freightways, Inc., 2019 IL App (1st) 172459 (Ill. App. Ct. 2019). “" To this end, plaintiff argues that, assuming arguendo that the sanctions were improper, because Howe did not submit special interrogatories to the jury to ascertain which of the six theories of negligence against it formed the basis of the jury's verdict, we cannot determine…”
Allen v. Sarah Bush Lincoln Health Ctr., 2021 IL App (4th) 200360 (Ill. App. Ct. 2021). “” 735 ILCS 5/2-1201(d) (West 2018). ¶ 120 “When there is a general verdict and more than one theory is presented, the verdict will be upheld if there was sufficient evidence to sustain either theory, and the [moving party], having failed to request special interrogatories,…”
Arient v. Alhaj-Hussein, 2017 IL App (1st) 162369 (Ill. App. Ct. 2017). “" 735 ILCS 5/2-1201(d) (West 2012). ¶ 45 In this case, the jury returned a general verdict, and because the defendants did not submit special interrogatories, we have no way of knowing upon which of the acts of negligence alleged against Dr.”
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