124 Ill. 2d 61 - Dralle v. Ruder’s Empirical Analysis
1988
Citation profile
8 federal appellate · 64 state decisions
How this case has been cited
Cited by 85 later decisions — most recently May 2025 · most notably Gallimore v. Children's Hospital Medical Center (1993), 209 Ill. 2d 76 - Vitro v. Mihelcic (2004)
8 federal appellate · 64 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 Santosky v. Kramer · Loving v. Commonwealth of Virginia · 22 Ill. 2d 73 - Knierim v. Izzo · 114 Ill. 2d 107 - Ballweg v. City of Springfield · 19 Cal. 3d 441 - Borer v. American Airlines, Inc.
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 85 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It is easy to see that the loss of a child through his death takes from his parents the society and companionship that is the existence of the lost relationship. But consider the magnitude of the loss of society and compansionship that occurs when a normal [child] is suddenly reduced to a blind, nearly deaf, partially paralyzed child with a mental age of three. The parental expectations for the continuation of the family relationship are the same in either case. That the parents still have their son to love and care for is a factor to consider in determining the extent of their loss, but does not negate the loss. They have sustained a genuine loss in the nature of the society and companionship they can anticipate receiving from their son as a consequence of his injuries. Perhaps the loss of companionship and society experienced by the parents of a child permanently and severely injured ... is in some ways even greater than that suffered by parents of a deceased child. Not only has the normal family relationship been destroyed, as when a child dies, but the parent is also confronted with his loss each time he is with the child and experiences again the child’s diminished capacity to given comfort, society, and companionship.”
1 later decision quote this exact passage · from the majority““Loss of society is an injury to familial relationships which has never been applied to relations among friends, or even to noncustodial relatives. Moreover, in the vast majority of cases, the child’s injuries will neither be so serious nor so permanent as to support a claim for loss of society.” Dralle, 124 Ill. 2d at 80 (Clark, J., specially concurring).”
1 later decision quote this exact passage · from the majority“"And our appellate court has consistently refused to recognize the converse claim — actions brought by children for loss of society and companionship resulting from nonfatal injuries to their parents.” Dralle v. Ruder, 124 Ill. 2d at 65 .”
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.