154 Ill. 2d 398 - Cunningham v. Huffman’s Empirical Analysis
1993
Citation profile
21 federal appellate · 111 state decisions
How this case has been cited
Cited by 144 later decisions — most recently September 2025 · most notably 199 Ill. 2d 325 - Belleville Toyota, Inc. v. Toyota Motor Sales, U.S.A., Inc. (2002), 223 Ill. 2d 49 - DeLuna v. Burciaga (2006)
21 federal appellate · 111 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 88 Ill. 2d 407 - Knox College v. Celotex Corp. · 85 Ill. 2d 146 - Witherell v. Weimer · 79 Ill. 2d 295 - Anderson v. Wagner · 73 Ill. 2d 113 - Towns v. Yellow Cab Co. · Page v. United States
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 144 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"[I]f the word occurrence were interpreted to mean a single isolated event, patients who discovered that they were gravely injured due to negligent or unnecessary exposure to X-ray radiation or administration of medication over a span of years might be able to recover little, if any, in the way of damages. This would be so because a single dosage of radiation or medicine might be harmless, whereas treatment over time might be either disabling or even fatal. * * * If the statute of repose were read to start on day one of the treatment in a span covering many years, a plaintiff could only seek recovery for the final four years. It is conceivable that the damage caused in the last four years might be either negligible or a small fraction of the harm caused over the continuum of negligence; thus, the recovery of damages would be negligible compared to the actual injury. Surely, the law could not contemplate such an unjust result." Cunningham, 154 Ill.2d at 405-06 , 182 Ill.Dec. 18 , 609 N.E.2d 321 .”
7 later decisions quote this exact passage · from the majority“`intended to terminate the possibility of liability after a defined period of time, regardless of a potential plaintiff's lack of knowledge.'”
3 later decisions quote this exact passage · from the majority““ ‘is intended to terminate the possibility of liability after a defined period of time, regardless of a potential plaintiffs lack of knowledge.’ [Citation.] Indeed, our legislature enacted this *** outer limit on malpractice liability specifically to curtail the ‘long tail’ exposure to medical malpractice claims brought about by the advent of the discovery rule. [Citation.] Thus, the statute of repose must be triggered once treatment terminates.” Cunningham v. Huffman, 154 Ill. 2d 398, 406 , 609 N.E.2d 321 (1993).”
2 later decisions 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.