362 Ill. App. 3d 984 - Bourgonje v. MacHev’s Empirical Analysis
2005
Citation profile
3 district · 62 state decisions
How this case has been cited
Cited by 74 later decisions — most recently January 2026 · most notably 371 Ill. App. 3d 682 - Jensen v. Bayer AG (2007), 378 Ill. App. 3d 219 - Jordan v. Knafel (2007)
3 district · 62 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 · 91 Ill. 2d 69 - Moorman Manufacturing Co. v. National Tank Co. · 31 Ill. 2d 69 - Nelson v. Union Wire Rope Corp. · 92 Ill. 2d 171 - Redarowicz v. Ohlendorf · 2 Ill. 2d 74 - Ney v. Yellow Cab Co.
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 74 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“One who undertakes, gratuitously or for consideration, to render services to another which he should recognize as necessary for the protection of the other's person or things, is subject to liability to the other for physical harm resulting from his failure to exercise reasonable care to perform his undertaking, if (a) his failure to exercise such care increases the risk of such harm, or (b) the harm is suffered because of the other's reliance upon the undertaking.”
6 later decisions quote this exact passage · from the majority““ ‘Reliance may reasonably be placed where there is a deceptive appearance that performance had been made, or where a representation of performance has been communicated to plaintiff by defendant, or where plaintiff is otherwise prevented from obtaining knowledge or substitute performance of the undertaking.’ [Citations.] Moreover, ‘to justify reliance, [a] plaintiff must be unaware of the actual circumstances and not equally capable of determining such facts.’ ” Bourgonje, 362 Ill. App. 3d at 1005 , 841 N.E.2d at 114-15 , quoting Chisolm v. Stephens, 47 Ill. App. 3d 999, 1007 , 365 N.E.2d 80, 86 (1977).”
2 later decisions quote this exact passage · from the majority“However, though a question of law, if there is a dispute of material fact affecting the existence of an undertaking of a duty, summary judgment is improper.”
2 later decisions 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.