Ruling’s impact has yet to hit Illinois

In its unanimous opinion in Cowper v. Nyberg, 2015 IL 117811 (filed March 19, 2015), the Illinois Supreme Court twice reiterated that a complaint should not be dismissed under Section 2-615 of the Illinois Code of Civil Procedure unless “it is clearly apparent that no set of facts can be proved that would entitle the plaintiff to recovery.” Id., ¶ 12; see also id., ¶ 22.On …

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