Illinois appellate courts

12 opinions this month · page 3 Civil

Monday, August 3, 2026 2 opinions

2026 IL App (1st) 251327 No. 2026 IL App (1st) 251327

Guess v. Board of Trustees of the Dolton Police Pension Fund

Rule 23 Civil Administrative Law

Pension applicant need only show duty-related incident was a causative factor, not the sole or primary cause of disability.
Board's denial of line-of-duty benefits reversed as against manifest weight where its own psychiatrist found direct causation.
Useful for pension/disability benefits attorneys and administrative law practitioners challenging boards' causation findings under manifest-weight review.

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2026 IL App (1st) 250741 No. 2026 IL App (1st) 250741

Sprolls v. Chevrolet

Rule 23 Civil Contract Law

First District affirms dismissal of vehicle sale claims where no signed writing existed and dealer never accepted or deposited buyer's payment
Court holds part-performance exception to UCC Statute of Frauds requires actual acceptance of payment, not merely tendering certified checks
Useful for commercial litigators handling failed vehicle/goods sales, Statute of Frauds defenses, and consumer fraud pleading standards in dealer disputes

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Friday, July 31, 2026 4 opinions

2026 IL App (5th) 250322 No. 2026 IL App (5th) 250322

Vida v. Wehking

Rule 23 Civil Administrative Law

Inmate's mandamus petition dismissed because trust account records lacked dates/hours worked, precluding sentence credit calculation
Mandamus requires plaintiff to plead every material fact establishing a clear right to relief, not just suggestive evidence
Useful for corrections/administrative law attorneys litigating inmate sentence credit disputes and mandamus pleading standards

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2026 IL App (1st) 242359 No. 2026 IL App (1st) 242359

Kos v. Muzykansky

Opinion Civil Tort Law

First District holds a treating specialist need not testify on causation if another qualified expert addresses how the injury would have been treated absent negligence.
Court affirms that expert testimony need not come from a physician in the same specialty as the alleged 'gap' area to establish proximate cause in a medical malpractice case.
Useful for medical malpractice litigators handling JNOV motions, expert qualification disputes, and cumulative-error new trial arguments involving evidentiary rulings.

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2026 IL App (1st) 250555 No. 2026 IL App (1st) 250555

Manzili v. Palos Hills Healthcare, LLC

Rule 23 Civil Contract Law

Settlement agreements require only objective manifestation of a meeting of the minds, even absent subjective intent to be bound.
Attorney's express authority to settle binds the client absent record evidence that authority was withdrawn or revoked.
Useful for civil litigators handling settlement enforcement disputes, pro se appeals, and Rule 341 briefing compliance issues.

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2026 IL App (1st) 252229 No. 2026 IL App (1st) 252229

Navarro-Angulo v. Police Board of the City of Chicago

Rule 23 Civil Administrative Law

Court affirms police applicant disqualification based on evidence of dishonesty, violent conduct, and application omissions under manifest weight standard.
Due process for administrative disqualification requires only notice and opportunity to respond in writing—no in-person hearing or confrontation rights required.
Useful for administrative law and public sector employment attorneys handling law enforcement hiring disqualifications and agency deference/due process challenges.

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Wednesday, July 29, 2026 1 opinion

2026 IL App (2d) 250530 No. 2026 IL App (2d) 250530

In re Estate of Megan

Rule 23 Civil Probate and Estate Law

Trial court's contempt finding affirmed based on credibility determinations and contradictory evidence of noncompliance with turnover orders.
Monetary sanction reversed because it lacked a valid purge condition and was compensatory, payable to a private party, not the public treasury.
Useful for probate litigators and civil practitioners handling indirect civil contempt proceedings, purge conditions, and enforcement of turnover orders.

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Tuesday, July 28, 2026 2 opinions

2026 IL App (1st) 251462 No. 2026 IL App (1st) 251462

Scott v. Illinois Human Rights Comm'n

Opinion Civil Administrative Law

IHRA's 30-day deadline to submit an EEOC determination to the Department is jurisdictional and cannot be equitably tolled, even where the agency initially overlooked it.
First District imposed $15,000 in Rule 375 sanctions on petitioner's attorney for submitting AI-hallucinated case citations and fabricated statutory quotations, plus ARDC referral.
Essential reading for employment/administrative law practitioners handling dual-filed EEOC/IDHR charges, and a cautionary case for any attorney using AI tools in legal research and brief-writing.

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2026 IL App (3d) 250533 No. 2026 IL App (3d) 250533

People v. 2008 Acura TLS

Rule 23 Civil Drug Crimes

Titled owner's uncorroborated testimony insufficient to prove innocent owner status when contrary evidence shows nominal ownership.
Court affirms forfeiture where claimant failed to produce loan documents and evidence showed vehicle purchased with drug proceeds.
Useful for attorneys handling drug asset forfeiture claims, innocent owner defenses, and evidentiary burden-of-proof challenges under 725 ILCS 150/9.1.

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Monday, July 27, 2026 1 opinion

2026 IL App (2d) 260089 No. 2026 IL App (2d) 260089

In re I.D

Rule 23 Civil Family Law

Second District affirms termination of parental rights, finding unfitness supported by lack of reasonable progress, interest, and efforts.
Court grants appellate counsel's Anders motion to withdraw, holding no non-frivolous issue exists on unfitness or best-interest findings.
Useful for family law practitioners handling termination-of-parental-rights appeals and evaluating Anders motions in juvenile/child welfare cases.

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Friday, July 24, 2026 2 opinions

2026 IL App (1st) 251182 No. 2026 IL App (1st) 251182

Fortner v. Illinois State Police

Rule 23 Civil Administrative Law

Applicant seeking relief from FOID/CCL denial under section 10(c) bears burden of proof, reviewed for abuse of discretion, not de novo
Circuit court properly denied relief where applicant had outstanding warrant, undisclosed criminal history, and lacked candor about his record
Useful for administrative law and firearms practitioners handling FOID/CCL denials, pro se appeals, and Rule 341 briefing deficiencies

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2026 IL App (1st) 260408 No. 2026 IL App (1st) 260408

In re L.B

Rule 23 Civil Family Law

Trial court's dispositional finding of parental unfitness upheld where father disengaged from court-ordered individual therapy for seven months.
Meaningful engagement and progress in reunification services—not mere completion—is essential; lapsed participation supports continued DCFS guardianship.
Useful for family law practitioners handling dispositional hearings, reunification service compliance disputes, and appeals of wardship/guardianship orders under the Juvenile Court Act.

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