Requests for Admission require the opposing party to admit whether certain facts are true, eliminating the need to prove those facts at trial. Under Illinois Supreme Court Rule 216, these Requests can be efficient tools to narrow the issues in dispute before trial. However, as the recipient of the request, you must take great care
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Supreme Court Reaffirms Strict Limits of Federal Jurisdiction in Removed Cases
Federal jurisdiction can disappear even after years of litigation, extensive discovery, and, in some cases, a completed trial. The U.S. Supreme Court underscored that reality in Hain Celestial Group, Inc. v. Palmquist, 607 U.S. 421 (2026), and Royal Canin U.S.A., Inc. v. Wullschleger, 604 U.S. 22 (2025). Although the cases involved different jurisdictional theories (diversity…
Illinois’ Proposed POWER Act: Implications for AI Data Centers, Developers, and Municipalities
As demand for artificial intelligence, cloud computing, and digital infrastructure continues to grow, Illinois lawmakers are considering legislation that could significantly impact data center development in the state. The proposed POWER Act (HB5513[i] and SB4016[ii]), short for the Protecting Our Water, Energy, and Ratepayers Act, seeks to address concerns about the energy…
English: The Official Language of Commercial Transportation
Background and Regulatory Context
Thirty states, including Illinois, have designated English as their official language. However, the United States doesn’t have a law establishing English as the country’s official language outside of an Executive Order. Nevertheless, the Federal Motor Carrier Safety Administration has effectively gained a new enforcement role: policing English language compliance.
In 2025,…
Appellate Court Expands Role of Insurance Appraisal Process to Include Causation Issues
The Case
Zhao[i] involved a coverage dispute over a homeowner’s hail damage claim and the cost of repair/replacement under the homeowner’s policy.
During the initial claims process, both sides obtained damage estimates. Those estimates reflected a sizeable gulf in covered damage. That dispute led to the policyholder invoking the policy’s appraisal provision, which the…
U.S. Supreme Court Unanimously Rules in Favor of Negligent Hiring Freight Broker Suits
The Case
Montgomery[i] involved a 2017 motor vehicle accident where an interstate motor carrier’s employee veered off Illinois Interstate 70 while driving a tractor-trailer on the job, ultimately striking a stopped driver, Shawn Montgomery, and causing Mr. Montgomery significant lasting injury and disfigurement. Montgomery’s leg ended up being amputated as a result of his…
Illinois Courts No Longer Excuse Late E-Filing
It Usually Works—Until It Doesn’t
Illinois courts used to show some leniency when attorneys missed filing deadlines because of electronic filing issues. That window may be closed. As the e‑filing system has matured, so has the judiciary’s expectation that practitioners understand it and follow its rules. Recent case law makes clear that Rule 9 is…
Generative AI: Practical Advice for Trial Lawyers
Trial lawyers really have little choice; they must adapt to the changing technology environment or fall behind. But recent court guidance reveals that in important areas, old rules still apply to new challenges posed by using artificial intelligence, even if the adequacy of old rules is debatable. So far, courts are not creating a special…
Beyond the Signature: Context, Timing, and Continued Judicial Scrutiny of Hospital Consent Forms in Apparent Agency Claims
What the Martin v. Layman Decision Adds
Illinois’ Fourth District Appellate Court’s decision in Martin v. Layman[1] continues a line of Illinois cases that closely examine whether hospital consent forms effectively disclaim apparent agency in emergency care settings. Relying in part on the First District’s reasoning in Brayboy v. Advocate Health & Hospitals Corp.,…
ITT at 33: Granting Summary Judgment in Missouri is Still Not “Extreme or Drastic”
The Case
Wilkinson v. Farmers Holding Companies involved a dispute under a Missouri statute about an employee’s post-termination rights to a “service letter” stating the nature and duration of his service. The Circuit Court granted summary judgment for the company based on the company’s argument that it was not the actual employer. The Supreme Court’s…