144 Ill. App. 3d 968 - Nguyen v. Tilwalli’s Empirical Analysis
1986
Citation profile
25 state decisions
How this case has been cited
Cited by 31 later decisions — most recently January 2026 · most notably 166 Ill. 2d 337 - Pasquale v. Speed Products Engineering (1995), 197 Ill. App. 3d 543 - Giordano v. Morgan (1990)
25 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 81 Ill. 2d 571 - People v. Rogers · 104 Ill. 2d 317 - Rakowski v. Lucente · 76 Ill. 2d 353 - Peterson v. Lou Bachrodt Chevrolet Co. · 101 Ill. 2d 535 - In Re Levin · 81 Ill. 2d 548 - Dial v. City of O'Fallon
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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““When a release or covenant not to sue or not to enforce judgment is given in good faith to one or more persons liable in tort arising out of the same injury *** it reduces the recovery on any claim against the others to the extent of any amount stated in the release or the covenant, or in the amount of the consideration actually paid for it, whichever is greater.””
3 later decisions quote this exact passage · from the majority“Plaintiff also argues that the result of the setoff is inequitable since the settling codefendants then bear the full burden for his injury while defendant, the only party determined to be at fault, pays nothing. Plaintiff contends this result is tantamount to a contribution to that defendant from the settling codefendants, contrary to Section 2(d) of the Contribution Among Joint Tortfeasors Act (Ill. Rev.Stat.1985, ch. 70, par 302(d)), which states, “[t]he tortfeasor who settles with a claimant pursuant to paragraph (c) is discharged from all liability for any contribution to any other tortfeasor.” However, section 2(c) of the Act specifically provides for and allows setoffs such as occurred here. Moreover, the theory of recovery in a negligence action is focused upon compensation to the plaintiff for his injuries, not punishment to the defendant (Peterson v. Lou Bachrodt Chevrolet Co. (1979), 76 Ill.2d 353, 363 , 29 Ill.Dec. 444 , 392 N.E.2d 1 ; Webb v. Toncray (1981), 102 Ill.App.3d 78, 80 , 57 Ill.Dec. 757 , 429 N.E.2d 874 ), and a plaintiff who has recovered for his damages has no basis to complain because a defendant benefitted from the setoff.”
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.