341 Ill. App. 3d 694 - Geary v. Telular Corp.’s Empirical Analysis
2003
Citation profile
3 federal appellate · 40 state decisions
How this case has been cited
Cited by 60 later decisions — most recently June 2023 · most notably 395 Ill. App. 3d 362 - Madden v. F.H. Paschen/S.N. Nielson, Inc. (2009), 364 Ill. App. 3d 6 - MC Baldwin Financial Co. v. DiMaggio, ROSARIO & VERAJA, LLC (2006)
3 federal appellate · 40 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 154 Ill. 2d 90 - Outboard Marine Corp. v. Liberty Mutual Insurance · 74 Ill. 2d 172 - Kelsay v. Motorola, Inc. · 85 Ill. 2d 124 - Palmateer v. International Harvester Co. · 102 Ill. 2d 468 - Jenkins v. Wu · 164 Ill. 2d 29 - Zimmerman v. Buchheit of Sparta, Inc.
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 60 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Illinois courts have applied the tort of retaliatory discharge in only two situations: (1) where the discharge stems from asserting a worker’s compensation claim (Kelsay v. Motorola, Inc., 74 Ill. 2d 172 , 384 N.E.2d 353 (1978)) and (2) where the discharge is for certain activities referred to as ‘whistle-blowing’ (Palmateer v. International Harvester Co., 85 Ill. 2d 124 , 421 N.E.2d 876 (1981) (Palmateer)). Jacobson v. Knepper & Moga, P.C., 185 Ill. 2d 372 , 706 N.E.2d 491 (1998). Other than these two circumstances, however, Illinois courts consistently have refused to expand the tort to encompass a private and individual grievance. See Price v. Carmack Datsun, Inc., 109 Ill. 2d 65 , 485 N.E.2d 359 (1985); McGrath v. CCC Information Services, Inc., 314 Ill. App. 3d 431 , 731 N.E.2d 384 (2000) (McGrath); Eisenbach v. Esformes, 221 Ill. App. 3d 440 , 582 N.E.2d 196 (1991); Abrams v. Echlin Corp., 174 Ill. App. 3d 434 , 528 N.E.2d 429 (1988) (Abrams).” Geary v. Telular Corp., 341 Ill. App. 3d 694, 701 , 793 N.E.2d 128, 134 (2003).”
1 later decision quote this exact passage · from the majority“There is no precise definition of the term. In general, it can be said that public policy concerns what is right and just and what affects the citizens of the State collectively. It is to be found in the State’s constitution and statutes and, when they are silent, in its judicial decisions. Although there is no precise line of demarcation dividing matters that are the subject of public policies from matters purely personal, a survey of cases in other States involving retaliatory discharges shows that a matter must strike at the heart of a citizen’s social rights, duties, and responsibilities before the tort will be allowed.”
1 later decision quote this exact passage · from the majority“The appellate court may affirm the grant of summary judgment for any reason that appears in the record, regardless of whether that reason is the reason relied upon by the circuit court.”
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.