189 Ill. 2d 603 - Clay v. Kuhl’s Empirical Analysis

2000

Citation profile

151

cited by 151 later decisions

states following

December 2025

most recently cited

12 federal appellate · 98 state decisions

How this case has been cited

Cited by 151 later decisions — most recently December 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)

12 federal appellate · 98 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 Urie v. Thompson · 88 Ill. 2d 407 - Knox College v. Celotex Corp. · 176 Ill. 2d 179 - In Re Chicago Flood Litigation · 85 Ill. 2d 161 - Nolan v. Johns-Manville Asbestos · 85 Ill. 2d 146 - Witherell v. Weimer

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 151 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

“'[e]quitable tolling of a statute of limitations may be appropriate if the defendant has actively misled the plaintiff, or if the plaintiff has been prevented from asserting his or her rights in some extraordinary way, or if the plaintiff has mistakenly asserted his or her rights in the wrong forum.'”
3 later decisions quote this exact passage · from the majority
e.g. In re Estate of Cerami · 314 F. Supp. 3d 999 - Richardson v. City of Chi.
“"The plaintiff correctly concede[d] that if her action was already barred under the common law discovery rule prior to the enactment of section 13-202.2, then the new statute could not have revived it; under Illinois law, the barring of an action by a statute of limitations creates a vested right in favor of the defendant, and the action cannot later be revived. [Citations.]" Clay, 189 Ill.2d at 609 , 244 Ill.Dec. 918 , 727 N.E.2d at 221 .”
2 later decisions quote this exact passage · from the majority
e.g. Mk v. Lc · M.K. v. L.C.
“Illinois law presumes an intent to harm and resulting injury”
2 later decisions quote this exact passage · from the majority
e.g. 406 Ill. App. 3d 1119 - Wisniewski v. Diocese of Belleville · 358 Ill. Dec. 359 - Schlosser v. State

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.