69 Ill. 2d 135 - Howlett v. Scott’s Empirical Analysis
1977
Citation profile
98 state decisions
How this case has been cited
Cited by 102 later decisions — most recently March 2025 · most notably Abor v. Black (1985), 136 Ill. 2d 513 - People Ex Rel. Chicago Bar Ass'n v. State Board of Elections (1990)
98 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 New York Times Co. v. Sullivan · Barr v. Matteo · Eccles v. Peoples Bank of Lakewood Village · Howard v. United States · 66 Ill. 2d 371 - Underground Contractors Ass'n v. City of Chicago
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 102 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"We have recently discussed the requirement of an actual controversy in Underground Contractors Association v. City of Chicago (1977), 66 Ill.2d 371 . There we said: `"Actual" in this context does not mean that a wrong must have been committed and injury inflicted. Rather, it requires a showing that the underlying facts and issues of the case are not moot or premature, so as to require the court to pass judgment on mere abstract propositions of law, render an advisory opinion, or give legal advice as to future events. [Citations.] The case must, therefore, present a concrete dispute admitting of an immediate and definitive determination of the parties' rights, the resolution of which will aid in the termination of the controversy or some part thereof. [Citations.]' ( 66 Ill.2d 371, 375 .)" ( 69 Ill.2d 135, 141-42 .)”
6 later decisions quote this exact passage · from the majority““Normally, a declaration of nonliability for past conduct is not a function of the declaratory judgment statute (see Cunningham Brothers, Inc. v. Bail (7th Cir. 1969), 407 F.2d 1165 , 1169, cert, denied (1969), 395 U.S. 959 , 23 L. Ed. 2d 745 , 89 S. Ct. 2100 ; Hanes Corp. v. Millard (D.C. Cir. 1976), 531 F.2d 585 ), for in those cases a potential defendant’s institution of a declaratory action deprives the potential plaintiff of his right to determine whether he will file, and, if so, when and where.” 69 Ill. 2d 135, 143 .”
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.