52 Ill. App. 3d 454 - Blakey v. Commonwealth Edison Co.’s Empirical Analysis

Citation profile

24 state decisions

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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““ ‘Proper venue is an important privilege which is given great weight in Illinois. For example, it was held in MartinTrigona v. Roderick (1975), 29 Ill. App. 3d 553 , 331 N.E.2d 100 , that a waiver of venue clause in a lease is void as contrary to public policy. *** “The legislature clearly meant to protect a defendant against being sued in a county arbitrarily selected by a plaintiff, wherein the defendant does not reside, or in which no part of the transaction occurred which gave rise to the cause of action. If a plaintiff could so select the county to bring his suit, obviously a defendant would be entirely at his mercy, since such an action could be made oppressive and unbearably costly.” ( 329 Ill. App. 408, 414 , 69 N.E.2d 97, 99 .)”

   3 later decisions quote this exact passage · from the majority
   e.g. 102 Ill. 2d 250 - Stambaugh v. International Harvester Co. · 137 Ill. App. 3d 7 - Hines v. Dresser Industries, Inc.

2. ““In any action involving defendants residing in different counties in which venue is based on residence and an appropriate and timely motion to transfer is made by a defendant not residing in the county, the overruling of the motion is not ground for reversal if he or she proceeds to trial on the merits, unless he or she renews the motion at the close of all the evidence and it appears from the record or the evidence that the defendant residing within the county was joined without probable cause and not in good faith for the purpose of obtaining a judgment against him or her but solely for the purpose of fixing venue in that county.” Ill. Rev. Stat. 1985, ch. 110, par. 2— 105.”

   2 later decisions quote this exact passage · from the majority
   e.g. 176 Ill. App. 3d 378 - Webb v. Morgan · 110 Ill. App. 3d 816 - Hartung v. Central Illinois Public Service Co.

3. “‘The Practice Act *** provides that a defendant shall not be sued in actions like this, outside the county of his residence. There are exceptions, of which the only one pertinent here is that the suit may be in the county where the transaction, or some part thereof, occurred. This is a valuable privilege conferred upon the defendant, which he may waive, but his right to insist upon it in apt time by proper objection, motion or plea, has always been recognized. ***’ ” (Emphasis in original.) Blakey v. Commonwealth Edison Co. (1977), 52 Ill. App. 3d 454, 456 .”

   1 later decision quote this exact passage · from the majority
   e.g. 102 Ill. 2d 250 - Stambaugh v. International Harvester Co.