120 Ill. App. 3d 475 - Evanik v. Janus’s Empirical Analysis
1983
Citation profile
35 state decisions
How this case has been cited
Cited by 35 later decisions — most recently February 2026 · most notably 311 Ill. App. 3d 139 - Buckner v. Causey (1999), Carroll v. Meredith (2001)
35 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Chicago Title & Trust Co v. Wabash-Randolph Corp. · Finn v. Williams · 6 Ill. 2d 577 - Allendorf v. Daily · 77 Ill. App. 3d 835 - Lawson v. Hill · Waller v. Hildebrecht
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"A way of necessity is a particular kind of implied easement. The concept was apparently first noted in Illinois in the case of Gilfoy v. Randall (1916), 274 Ill. 128 , 113 N.E. 88 , and later expanded in Finn v. Williams (1941), 376 Ill. 95 , 33 N.E.2d 226 . Plaintiffs rely heavily on the Finn case in support of their position. The facts of Finn are similar to those of the instant case. The property at issue in Finn was at one time owned entirely by Williams who sold Finn the northwest corner of it. The property purchased by Finn abutted no public roads. At trial, he claimed that the only means of ingress and egress to his property was a road which crossed the remaining property of Williams. Williams denied this. The court found that other private roads had been in existence since the time of the original severance but that those means of access had been closed or were no longer in existence. At the time of trial, the only access to a highway (as indicated by testimony of defendant’s witnesses) was a road across defendant’s land which was now denied to plaintiff. Based on these circumstances, the trial court found that an easement existed across the defendant’s lands. On appeal, the defendant urged that private roads had supplied the plaintiff access to the property for a long period of time and so no necessity was proved either at the time of severance or the time of trial. The plaintiff replied that changed circumstances had created a necessity for a way to a public road a”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.