196 Ill. App. 3d 727 - Schaffer v. Zekman’s Empirical Analysis
1990
Citation profile
20 federal appellate · 56 state decisions
How this case has been cited
Cited by 88 later decisions — most recently September 2024 · most notably 174 Ill. 2d 77 - Bryson v. News America Publications, Inc. (1996), 154 Ill. 2d 1 - Kolegas v. Heftel Broadcasting Corp. (1992)
20 federal appellate · 56 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 Time, Inc. v. Hill · 126 Ill. 2d 411 - Lovgren v. Citizens First National Bank · 113 Ill. 2d 273 - Owen v. Carr · 42 Cal. 3d 234 - Fellows v. National Enquirer, Inc. · Brown & Williamson Tobacco Corp. v. Jacobson
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 88 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A publication is defamatory per se if it is 'so obviously and naturally harmful to the person to whom it refers that a showing of special damages is unnecessary' (Owen v. Carr (1986), 113 Ill.2d 273, 277, 100 Ill.Dec. 783, 497 N.E.2d 1145); the defamatory character of the statement is apparent on its face, and extrinsic facts are not necessary to explain. (Brown & Williamson Tobacco Corp. v. Jacobson (7th Cir.1983), 713 F.2d 262 , 267.) Statements are actionable per quod if they necessitate extrinsic facts or innuendo to explain their defamatory meaning, and require evidence demonstrating, as a matter of fact, that some substantial injury resulted to the aggrieved person from their use. Heerey v. Berke (1989), 188 Ill.App.3d 527, 532, 136 Ill.Dec. 262, 544 N.E.2d 1037.”
1 later decision quote this exact passage · from the majority““In reviewing the circuit court’s dismissal, this court must accept as true all well-pleaded facts in the complaint and all reasonable inferences which can be drawn therefrom to determine, as a matter of law, whether the pleadings state a cause of action.' (Harris Trust & Savings Bank v. Phillips (1987), 154 Ill. App. 3d 574, 579 , 506 N.E.2d 1370 .) Conclusions of law or conclusions of fact not supported by allegations of specific facts will not be considered. Davis v. Keystone Printing Service, Inc. (1982), 111 Ill. App. 3d 427, 433 , 444 N.E.2d 253 .””
1 later decision quote this exact passage · from the majority“`the injurious character of the statement * * * cannot be considered so obvious as to justify dispensing with proof of actual damages' [ i.e., the statement cannot be libelous per se ] where additional explanation is required to establish a person's identification with the publication.”
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.