183 Ill. 2d 272 - Doe v. McKay’s Empirical Analysis
1998
Citation profile
68 state decisions
How this case has been cited
Cited by 69 later decisions — most recently May 2025 · most notably 209 Ill. 2d 76 - Vitro v. Mihelcic (2004), 197 Ill. 2d 60 - Norskog v. Pfiel (2001)
68 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 156 Ill. 2d 76 - Cates v. Cates · 137 Ill. 2d 332 - O'HARA v. Holy Cross Hospital · 32 Ill. 2d 465 - Nix v. Smith · 225 Ill. App. 3d 509 - Cates v. Cates
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 69 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A number of considerations relevant to the duty analysis strongly militate against imposition of duty here .... Approval of the plaintiff's cause of action ... would mean that therapists generally, as well as other types of counselors, could be subject to suit by any nonpatient third party who is adversely affected by personal decisions perceived to be made by a patient in response to counseling. This result would, we believe, place therapists in a difficult position, requiring them to answer to competing demands and to divide their loyalty between sharply different interests. Concern about how a course of treatment might affect third parties could easily influence the way in which therapists treat their patients. Under a rule imposing a duty of care to third parties, therapists would feel compelled to consider the possible effects of treatment choices on third parties and would have an incentive to compromise their treatment because of the threatened liability. This would be fundamentally inconsistent with the therapist's obligation to the patient.... Hoping to avoid liability to third parties, ... a therapist might instead find it necessary to deviate from the treatment the therapist would normally provide, to the patient's ultimate detriment. This would exact an intolerable high price from the patient-therapist relationship and would be destructive of that relationship.”
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.