Merdelin Johnson v. Johnson & Bell, Ltd.
Feb 24, 2014OUTCOME: Judgment Affirmed
APPELLATE COURT OF ILLINOIS, FIRST DISTRICT, FIRST DIVISION 2014 IL App (1st) 122677 HOLDINGS: [1] The absolute litigation privilege applied to the patron's invasion of privacy claim because the r ... ules on absolute privilege applied to invasion of privacy suits as well; [2] The trial court did not err in finding that the patron's remaining claims in her amended complaint were also barred by the absolute litigation privilege; [3] There was no civil cause of action for misconduct which occurred in prior litigation, and the fact that neither court chose to assess sanctions against the store or its counsel did not provide an adequate basis for a civil action in state court based on the same conduct.
