144 Ill. 2d 232 - Beck v. Stepp’s Empirical Analysis
1991
Citation profile
99 state decisions
How this case has been cited
Cited by 104 later decisions — most recently August 2025 · most notably 197 Ill. 2d 514 - Steinbrecher v. Steinbrecher (2001), 321 Ill. App. 3d 509 - Twardowski v. Holiday Hospitality Franchising, Inc. (2001)
99 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 138 Ill. 2d 458 - Marsh v. Evangelical Covenant Church · 119 Ill. 2d 344 - Elg v. Whittington · 49 Ill. 2d 131 - Fultz v. Haugan · 79 Ill. App. 3d 1051 - Kooyenga v. Hertz Equipment Rentals, Inc. · 130 Ill. App. 2d 807 - Dauderman v. Dauderman
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 104 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The purpose of a nunc pro tunc order is to correct the record of judgment, not to alter the actual judgment of the court. A nunc pro tunc order may not be used to supply omitted judicial action, to correct judicial errors under the pretense of correcting clerical errors, or to cure a jurisdictional defect. (Kooyenga v. Hertz Equipment Rentals, Inc. (1979), 79 Ill. App. 3d 1051, 1056 .) Judgments may be modified nunc pro tunc only when the correcting order is based upon evidence such as a ‘note, memorandum or memorial paper remaining in the files or upon the records of the court.’ (Fox, 34 Ill. 2d at 360.) The evidence supporting a nunc pro tunc modification must clearly demonstrate that the order being modified fails to conform to the decree actually rendered by the court. Young, 414 Ill. at 534.””
4 later decisions quote this exact passage · from the dissent““A post-judgment motion must include a request for at least one of the forms of relief specified in section 2 — 1203. [Citations.] In addition, a post-judgment motion must allege grounds that would warrant the granting of the relief requested. (Andersen v. Resource Economics Corp. (1990), 133 Ill. 2d 342, 347 .) Finally, a post-judgment motion must be filed with the clerk of the court, and copies of the motion must be served upon all parties. (134 Ill. 2d R. 104(b).)” Beck, 144 Ill. 2d at 240 , 579 N.E.2d at 828 .”
1 later decision quote this exact passage · from the dissent““Nunc pro tunc orders must be based upon definite and precise evidence in the record. [Citation.] The certainty of evidence must be assured without reliance upon the memory of the judge or any other person, and a nunc pro tunc order cannot be based upon ex parte affidavits or testimony.” Beck v. Stepp, 144 Ill. 2d 232, 239 , 579 N.E.2d 824, 827 (1991).”
1 later decision quote this exact passage · from the dissent
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.