133 Ill. App. 2d 261 - Alsobrook v. Cote’s Empirical Analysis
1971
Citation profile
53 state decisions
How this case has been cited
Cited by 53 later decisions — most recently January 2015 · most notably 136 Ill. 2d 282 - Segal v. Sacco (1990), 70 Ill. App. 3d 929 - Licka v. William A. Sales, Ltd. (1979)
53 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 119 Ill. App. 2d 157 - Karpiel v. LASALLE NAT. BANK OF CHICAGO · 126 Ill. App. 2d 35 - Mosley v. Spears · 70 Ill. App. 2d 86 - Caliendo v. Public Taxi Service, Inc. · 35 Ill. App. 2d 360 - Bickson v. Bickson · 36 Ill. App. 2d 158 - Kohlhaas v. Morse
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 53 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““There is no fixed rule or absolute standard which can be universally applied to determine whether a plaintiff has exercised reasonable diligence to obtain service; each case, of necessity, must be judged and evaluated on its own peculiar facts and circumstances. Courts, however, in making a determination have looked to a number of factors including: (1) the length of time used to obtain service of process (Kohlhaas v. Morse, 36 Ill.App.2d 158 , 183 N.E.2d 16 ); (2) the activities of the plaintiff (Felton v. Coyle, 66 Ill.App.2d 4 , 214 N.E.2d 359 , Davis v. Anthony, 67 Ill.App.2d 226 , 214 N.E.2d 603 ); (3) any knowledge on the part of the plaintiff of the defendant’s location (Karpiel v. LaSalle National Bank of Chicago, 119 Ill.App.2d 157 , 255 N.E.2d 61 , Mosley v. Spears, 126 Ill.App.2d 35 , 261 N.E.2d 510 ); (4) the ease with which the defendant’s whereabouts could have been ascertained (Caliendo v. Public Taxi Service, Inc., 70 Ill.App.2d 86 , 217 N.E.2d 369 , Harvey v. Lippens, 87 Ill.App.2d 363 , 231 N.E.2d 613 ); (5) the actual knowledge by the defendant of the pendency of the action as the result of ineffective service (Hahn v. Wiggins, 23 Ill.App.2d 391 , 163 N.E.2d 562 , De Cicco v. Reed, 77 Ill.App.2d 349 , 222 N.E.2d 346 ); and (6) special circumstances which would affect the efforts made by the plaintiff. Hahn v. Wiggins, 23 Ill.App.2d 391 , 163 N.E.2d 562 .””
3 later decisions quote this exact passage · from the majority““If the plaintiff fails to exercise reasonable diligence to obtain service prior to the expiration of the applicable statute of limitations, the action as a whole or as to any unserved defendant may be dismissed without prejudice. If the failure to exercise reasonable diligence to obtain service occurs after the expiration of the applicable statute of limitations, the dismissal shall be with prejudice. In either case the dismissal may be made on the application of any defendant or on the court’s own motion.””
2 later decisions quote this exact passage · from the majority““The Rule [Illinois Supreme Court Rule 103(b)] does not set a specific time limitation within which a defendant must be served, but it does put the burden upon the plaintiff to show that he has exercised reasonable diligence to obtain service. Mosley v. Spears, 126 Ill.App.2d 35 , 261 N.E.2d 510 .””
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.