Illinois Compiled Statutes
735 ILCS 5/2-609 (2026)
Supplemental pleadings
✓ current as of May 2026
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(735 ILCS 5/2-609)
(from Ch. 110, par. 2-609)
Sec. 2-609.
Supplemental pleadings.
Supplemental pleadings, setting up matters which
arise after the original pleadings are filed, may be filed within a
reasonable time by either party by leave of court and upon terms.
(Source: P.A. 82-280.)
Notes of Decisions
Cited in 14
cases, 1997–2017 · leading case: Fischer v. Senior Living Props., L.L.C., 771 N.E.2d 505 (Ill. App. Ct. 2002).
Fischer v. Senior Living Props., L.L.C., 771 N.E.2d 505 (Ill. App. Ct. 2002). “2d 134 (1981), the case relied upon by Allen for the "nullity" language quoted above, involved the filing of a complaint as a supplemental pleading under section 2-609 of the Code (735 ILCS 5/2-609 (West 2000)). Section 2-609 specifically requires that a supplemental pleading be…”
Huon v. Johnson & Bell, Ltd., 657 F.3d 641 (7th Cir. 2011). “See 735 ILCS 5/2-609; see also Brzostowski v.”
Jones v. Prof'l Motorcycle Escort Serv., L.L.C., 193 S.W.3d 564 (Tenn. 2006). “Compare 735 ILCS 5/2-609 (2000) ("supplemental pleadings setting up matters which arise after the original pleadings are filed, may be filed within a reasonable time by either party by leave of court and upon terms.”
City of Joliet v. Szayna, 2016 IL App (3d) 150092 (Ill. App. Ct. 2017). “Sections 2-609 and 2-610 of the Code of Civil Procedure (735 ILCS 5/2-609 and 610) governs procedures of supplemental pleadings.”
McNerney v. Allamuradov, 2017 IL App (1st) 153515 (Ill. App. Ct. 2017). “6 ¶ 50 Third, we further note that McNerney’s utilization of the term “supplement” is inaccurate, given that Allamuradov’s application was submitted to and approved by Village years before the motions for summary judgment were filed. Section 2-609 provides that “[s]upplemental…”
McNerney v. Allamuradov, 2017 IL App (1st) 153515 (Ill. App. Ct. 2017). “6 ¶ 50 Third, we further note that McNerney’s utilization of the term “supplement” is inaccurate, given that Allamuradov’s application was submitted to and approved by the Village years before the motions for summary judgment were filed. Section 2-609 provides that…”
City of Joliet v. Szayna, 2016 IL App (3d) 150092 (Ill. App. Ct. 2016). “Rather, the lone authority cited by defendant is sections 2-609 and 2-610(a) of the Code of Civil Procedure (735 ILCS 5/2-609, 2-610(a) (West 2014)). While section 2-609 permits the amendment of pleadings and section 2-610(a) requires pleadings to be specific, defendant fails to…”
People v. White, 2017 IL App (1st) 130882 (Ill. App. Ct. 2017). “”); 735 ILCS 5/2-609 (West 2010) (“Supplemental pleadings, setting up matters which arise after the original pleadings are filed, may be filed within a reasonable time by either party by leave of court and upon terms.”
Bentley v. Hefti, 2015 IL App (4th) 140167 (Ill. App. Ct. 2015). “26, 2010), which calls upon us to answer the following certified question: “If a motion for leave to file a supplemental complaint pursuant to [section 2-609 of the Code of Civil Procedure (735 ILCS 5/2-609 (West 2012))] is filed with the proposed supplemental complaint attached…”
People v. White, 2017 IL App (1st) 130882 (Ill. App. Ct. 2017). “”); 735 ILCS 5/2-609 (West 2010) (“Supplemental pleadings, setting up matters which arise after the original pleadings are filed, may be filed within a reasonable time by either party by leave of court and upon terms.”
Bentley v. Hefti, 2015 IL App (4th) 140167 (Ill. App. Ct. 2015). “¶7 On August 28, 2013, one day before the expiration of the one-year statute of limi- tations for plaintiff's defamation claims against Marion, plaintiff filed (under the same case num- ber as his May 2012 complaint against defendants) a motion for leave to file a supplemental…”
Fischer v. Senior Living Props., L.L.C. (Ill. App. Ct. 2002). “2d 134 (1981), the case relied upon by Allen for the "nullity" language quoted above, involved the filing of a complaint as a supplemental pleading under section 2-609 of the Code (735 ILCS 5/2-609 (West 2000)). Section 2-609 specifically requires that a supplemental pleading be…”
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