Payne v. Mroz’s Empirical Analysis
1994
Citation profile
9 state decisions
How this case has been cited
Cited by 9 later decisions — most recently February 2026
9 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 48 Ill. 2d 580 - Fooden v. Board of Governors · 108 Ill. 2d 217 - Freeding-Skokie Roll-Off Service, Inc. v. Hamilton · 152 Ill. App. 3d 332 - Whitman v. Lopatkiewicz · 157 Ill. App. 3d 616 - Waite v. Chicago Transit Authority
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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"The mere happening of an accident does not entitle a plaintiff to recover. A plaintiff must come forward with evidence of negligence on the part of the defendant and with evidence that the defendant's negligence was a proximate cause of the plaintiff's injuries. Proximate cause can only be established when there is a reasonable certainty that the defendant's acts caused the injury. [Citation.] The test of summary judgment is the same as the test for a motion for a directed verdict. [Citation.] Although a plaintiff need not prove his entire case at the summary judgment stage, he must introduce evidence that would support a finding in his favor. In this case, at a trial, the plaintiff would be required to establish that it is more probably true than not true that [the decedent] was negligent in such a fashion that []he proximately caused the accident. It would not be enough that the plaintiff introduce evidence from which a fact finder could conjecture or guess or suspect that * * * [the decedent drove through a red light]." (Emphasis in original.) Payne v. Mroz, 259 Ill.App.3d 399, 403 , 197 Ill.Dec. 334 , 631 N.E.2d 337 (1994).”
2 later decisions quote this exact passage · from the majority“It is not necessary that only one conclusion follow from the evidence. [Citation.] However, a fact cannot be established through circumstantial evidence unless the circumstances are so related to each other that it is the only probable, and not merely possible, conclusion that may be drawn. [Citation.] That is, where the proven facts demonstrate that the nonexistence of the fact to be inferred appears to be just as probable as its existence, then the conclusion that exists is a matter of speculation, surmise, and conjecture, and the trier of fact cannot be permitted to make that inference.”
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.