207 Ill. App. 3d 665 - Toth v. Mansell’s Empirical Analysis
1991
Citation profile
10 federal appellate · 17 state decisions
How this case has been cited
Cited by 48 later decisions — most recently November 2025 · most notably 174 Ill. 2d 281 - Armstrong v. Guigler (1996), Delta Consulting Group, Inc. v. R. Randle Construction, Inc. (2009)
10 federal appellate · 17 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 106 Ill. App. 3d 1046 - La Grange Metal Products v. Pettibone Mulliken Corp. · 132 Ill. App. 3d 260 - W. E. Erickson Construction, Inc. v. Congress-Kenilworth Corp. · Plumb v. Campbell · 85 Ill. App. 3d 203 - Ames v. Crown Life Insurance Co. of Toronto, Canada · 53 Ill. App. 3d 935 - Motive Parts Co. of America, Inc. v. Robinson
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 48 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Illinois courts strictly interpret the meaning of a written contract and ‘other evidence of indebtedness’ within the statute of limitations. A contract is considered written for purposes of the statute of limitations if all essential terms are reduced to writing and can be ascertained from the instrument itself. [Citations.] If parol evidence is necessary to make the contract complete, then the contract must be treated as oral for purposes of the statute of limitations. [Citations.] Similarly, a written document qualifies as ‘other evidence of indebtedness’ under section 13 — 206 only when one need not resort to parol evidence to establish the vital elements of the agreement.” Toth, 207 Ill. App. 3d at 669-70 .”
4 later decisions quote this exact passage · from the majority“If parol evidence is necessary to make the contract complete, then the contract must be treated as oral for purposes of the statute of limitations.”
2 later decisions quote this exact passage · from the majority“a writing that satisfies the statute of frauds requirements does not necessarily satisfy the statute of limitations definition of a written contract.”
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.