Illinois Compiled Statutes
735 ILCS 5/2-612 (2026)
Insufficient pleadings
✓ current as of May 2026
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(735 ILCS 5/2-612)
(from Ch. 110, par. 2-612)
Sec. 2-612.
Insufficient pleadings.
(a) If any pleading is insufficient in substance or form the court
may order a fuller or more particular statement. If the pleadings do not
sufficiently define the issues the court may order other pleadings
prepared.
(b) No pleading is bad in substance which contains such information
as reasonably informs the opposite party of the nature of the claim or
defense which he or she is called upon to meet.
(c) All defects in pleadings, either in form or substance, not
objected to in the trial court are waived.
(Source: P.A. 82-280.)
Notes of Decisions
Cited in 73
cases (19 in the last 5 years), 1994–2026 · leading case: Connick v. Suzuki Motor Co., Ltd., 675 N.E.2d 584 (Ill. 1996).
Connick v. Suzuki Motor Co., Ltd., 675 N.E.2d 584 (Ill. 1996). “Under the Code of Civil Procedure, "[n]o pleading is bad in substance which contains such information as reasonably informs the opposite party of the nature of the claim or defense which he or she is called upon to meet.”
Vogt v. Round Robin Enter., Inc., 2020 IL App (4th) 190294 (Ill. App. Ct. 2021). “735 ILCS 5/2-612(a) (West 2016). The section further provides, “[n]o pleading is bad in substance which contains such information as reasonably informs the opposite party of the nature of the claim or defense which he or she is called upon to meet.”
Mason v. Snyder, 774 N.E.2d 457 (Ill. App. Ct. 2002). “The court responded that such a motion had been made, but the reviewing court noted that, in fact, no such motion had been made. In this context, the First District Appellate Court wrote the following: "There is little question that a trial court has the authority, on its own…”
Anderson v. Vanden Dorpel, 667 N.E.2d 1296 (Ill. 1996). “The Code provides simply that the complaint "shall contain a plain and concise statement of the pleader's cause of action.”
Rocha v. FedEx Corp., 2020 IL App (1st) 190041 (Ill. App. Ct. 2021). “Under section 2-612(a) of the Code (735 ILCS 5/2-612(a) (West 2014)), “[i]f any pleading is insufficient in substance or form the court may order a fuller or more particular statement” or “[i]f the pleadings do not sufficiently define the issues the court may order other…”
In Re Kenneth D., 847 N.E.2d 544 (Ill. App. Ct. 2006). “Initially, respondent never objected to the allegations set forth in the petition for adjudication of wardship, which included her failure to obtain prenatal care, and never moved to strike those allegations before the trial court.”
Grove v. Carle Found. Hosp., 846 N.E.2d 153 (Ill. App. Ct. 2006). “735 ILCS 5/2-612(b) (West 2004). Under section 2-616, pleadings may be amended at any time, even after judgment.”
Check v. Clifford Chrysler-Plymouth of Buffalo Grove, Inc., 794 N.E.2d 829 (Ill. App. Ct. 2003). “" 735 ILCS 5/2-612(c) (West 1996). Under the doctrine of aider by verdict, a jury verdict cures not only all formal and purely technical defects in the complaint, but any defect in failing to allege or alleging imperfectly any substantial facts which are essential to the cause…”
People v. $1,124,905 U.S. Currency, 685 N.E.2d 1370 (Ill. 1997). “" 735 ILCS 5/2-612(b) (West 1994). Although abandoning technical forms of pleading, Illinois remains a fact-pleading state.”
Rodgers v. Whitley, 668 N.E.2d 1023 (Ill. App. Ct. 1996). “In this case, count I of the amended complaint clearly informs defendants of the nature of plaintiffs' claim, and it even provides an example of the sort of evidence plaintiffs *1030 intend to present to support their claim.”
Welsh v. Commonwealth Edison Co., 713 N.E.2d 679 (Ill. App. Ct. 1999). “" It is the degree of emotional distress actually suffered by a plaintiff which separates the actionable from the non-actionable. Illinois is a fact pleading jurisdiction.”
In Re Kenneth J., 817 N.E.2d 940 (Ill. App. Ct. 2004). “2d 1175 ; 735 ILCS 5/2-612(c) (West 2002). *945 Respondent relies on two cases in support of her argument that she did not waive review of this issue because the State's petition failed to state a cause of action, which she may raise at any time: In re Rauch, 45 Ill.”
— 735 ILCS 5/2-612(a) — 12 cases
Mason v. Snyder, 774 N.E.2d 457 (Ill. App. Ct. 2002). “The court responded that such a motion had been made, but the reviewing court noted that, in fact, no such motion had been made. In this context, the First District Appellate Court wrote the following: "There is little question that a trial court has the authority, on its own…”
Rocha v. FedEx Corp., 2020 IL App (1st) 190041 (Ill. App. Ct. 2021). “Under section 2-612(a) of the Code (735 ILCS 5/2-612(a) (West 2014)), “[i]f any pleading is insufficient in substance or form the court may order a fuller or more particular statement” or “[i]f the pleadings do not sufficiently define the issues the court may order other…”
Vogt v. Round Robin Enter., Inc., 2020 IL App (4th) 190294 (Ill. App. Ct. 2021). “735 ILCS 5/2-612(a) (West 2016). The section further provides, “[n]o pleading is bad in substance which contains such information as reasonably informs the opposite party of the nature of the claim or defense which he or she is called upon to meet.”
Gaylord v. Presence Pain Care, 2023 IL App (3d) 210572-U (Ill. App. Ct. 2023).
Tejada v. Barreiro, 2022 IL App (2d) 210696-U (Ill. App. Ct. 2022).
— 735 ILCS 5/2-612(b) — 31 cases
Connick v. Suzuki Motor Co., Ltd., 675 N.E.2d 584 (Ill. 1996). “Under the Code of Civil Procedure, "[n]o pleading is bad in substance which contains such information as reasonably informs the opposite party of the nature of the claim or defense which he or she is called upon to meet.”
Anderson v. Vanden Dorpel, 667 N.E.2d 1296 (Ill. 1996). “The Code provides simply that the complaint "shall contain a plain and concise statement of the pleader's cause of action.”
Grove v. Carle Found. Hosp., 846 N.E.2d 153 (Ill. App. Ct. 2006). “735 ILCS 5/2-612(b) (West 2004). Under section 2-616, pleadings may be amended at any time, even after judgment.”
People v. $1,124,905 U.S. Currency, 685 N.E.2d 1370 (Ill. 1997). “" 735 ILCS 5/2-612(b) (West 1994). Although abandoning technical forms of pleading, Illinois remains a fact-pleading state.”
Rodgers v. Whitley, 668 N.E.2d 1023 (Ill. App. Ct. 1996). “In this case, count I of the amended complaint clearly informs defendants of the nature of plaintiffs' claim, and it even provides an example of the sort of evidence plaintiffs *1030 intend to present to support their claim.”
— 735 ILCS 5/2-612(c) — 28 cases
In Re Kenneth D., 847 N.E.2d 544 (Ill. App. Ct. 2006). “Initially, respondent never objected to the allegations set forth in the petition for adjudication of wardship, which included her failure to obtain prenatal care, and never moved to strike those allegations before the trial court.”
Check v. Clifford Chrysler-Plymouth of Buffalo Grove, Inc., 794 N.E.2d 829 (Ill. App. Ct. 2003). “" 735 ILCS 5/2-612(c) (West 1996). Under the doctrine of aider by verdict, a jury verdict cures not only all formal and purely technical defects in the complaint, but any defect in failing to allege or alleging imperfectly any substantial facts which are essential to the cause…”
In Re Kenneth J., 817 N.E.2d 940 (Ill. App. Ct. 2004). “2d 1175 ; 735 ILCS 5/2-612(c) (West 2002). *945 Respondent relies on two cases in support of her argument that she did not waive review of this issue because the State's petition failed to state a cause of action, which she may raise at any time: In re Rauch, 45 Ill.”
In Re Jerome F., 757 N.E.2d 905 (Ill. App. Ct. 2001).
People ex rel. Schad, Diamond & Shedden, P.C. v. My Pillow, Inc., 2017 IL App (1st) 152668 (Ill. App. Ct. 2017).
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