Car Accident Lawyer Chicago Team
Automobile accidents happen every day, in every city of the country – including Chicago. They’re one of the most common kinds of cases our team takes. With an office in downtown Chicago, our car accident lawyer team in Chicago handles car, motorcycle and truck accident cases – and our nationwide resources mean we can deliver you first-class representation.
When we at the Lamber Goodnow Team take your case, it’s an investment in you. Our team of lawyers, legal assistants, partner law firms, expert consultants, reconstructionists and other professionals works together to develop a strategy, represent you and your family, and fight for you – no matter how big the insurance company on the other side. Our experience in litigating car accident legal cases in Illinois is unparalleled, and our track record handling cases that range from injuries to fatalities is held in high regard across the country.
We’ll manage every aspect of your motor vehicle accident case – filing reports and briefs, conducting investigations, interviewing experts and witnesses, and coaching you through the process. We’ll develop a strategy specific to your auto accident case and your personal needs – that’s why we’re so innovative. Every case, just like every person, is unique.
We represent clients across Illinois. From our first contact, we’ll act quickly and responsibly to get you the help you deserve.
Learn more about how you can maximize your legal recovery in these types of accidents:
- Uninsured and Underinsured Motorist
- Cellphone Use / Texting While Driving Accidents
- Motorcycle Accidents
- Rollover Accidents
- Rear-End Collision
- Head-On Collisions
Auto Accident Incidents in Chicago
Cook County is one of the most dangerous places in Illinois to drive. According to the CDC, nearly 3,000 people died in auto accidents in Cook County from 2004 to 2010 – that’s nearly a person every day. Each of those accidents had ramifications on families and careers. Each of those people needed a qualified, reliable attorney to represent their families and help them through the aftermath of the crash in Chicago.
Simply being a conscientious driver and following motor vehicle laws isn’t enough to keep yourself, or your family, safe. Unfortunately, car accidents happen every day in Chicago. And if you’re injured, it’s imperative that you have someone fighting for your wrights.
Why Every Second Matters in Automobile Accidents
If you’re in a wreck, every second after the collision matters. Every single second. Our team will join forces with our partners to preserve any evidence from you or at the scene, interview witnesses, obtain all police reports and documentation, and send expert reconstructionists to understand every facet of your accident. We’re leaders in our industry – our process isn’t just innovative, it’s also extremely successful. The sooner you contact us, the faster we’ll be able to start working for you.
You Have Car Accident Questions – Lamber Goodnow Has The Answers
What do I do if I am in an automobile accident?
If you are involved in an automobile accident do not leave the scene; otherwise, you may be charged criminally.
- The first thing you should do is call an ambulance if you, or someone involved in the accident, is injured.
- Once you have taken proper health precautions, you should call the police and file an accident report.
- When speaking to the police never admit liability (fault), limit yourself to discussing the facts, as liability will be investigated later.
While at the accident scene, make sure to collect the names, phone numbers and addresses of any witnesses, or other people involved in the accident. If you speak to witnesses, or others involved in the accident, take notes of the conversation. It is also helpful to take pictures (most people will have a camera on their cellphone) for documentation purposes. Take photos of injuries, road obstructions, skid marks, vehicle damage and anything else that seems relevant.
If you have been injured in the accident, make sure you receive medical treatment for your injuries as soon as possible. Seeing a medical professional is important to begin immediate treatment, as well as to document your injuries from the automobile accident. In addition to the doctor’s records, make sure to write down the extent of your injuries (mental and physical). This may include medical treatment you have received (doctor, physical therapist and therapist), as well as the effect your injuries have had on your professional, social and personal life.
It is also important to consider writing down a detailed description of what happened before, during and after the accident that led to your injury. Important things to note include: the time of the injury, the place of the injury, the weather conditions, who was there, how the incident played out, what was said, what you experienced during and after the accident, and anything else you feel is important.
If you have injuries resulting from the accident you should speak with a car accident lawyer in Chicago as soon as possible. Many times facts become hazy, witnesses move, and insurance company’s adjusters ask questions in a manner that may hurt your claim. An experienced attorney will be able to analyze the information you have gathered, provide guidance and advise you whether you have a viable personal injury claim.
Is it okay for me to speak to the police when they arrive at the scene of the accident?
Yes, you should speak to the police. However, whether you are the victim of an accident, or the cause of the accident, limit your conversation with the police to discussing the facts. Never admit liability (fault) or make accusations, as liability will be investigated at a later time.
Do I need a police report and if so, how do I obtain one?
If you were involved in an automobile accident in which a police officer responded, a police report was likely created. This report may be a helpful tool to gain leverage in informal settlement discussions with an insurance carrier or opposing counsel in your personal injury dispute.
The police report may be used to gain knowledge of certain circumstances of the accident, such as time of day, the specific location of the accident, date, and weather conditions at the time of the accident. Additionally, it may contain the police officer’s primary assessment of fault. The assessment would include the responding officer’s observations as to whether the driver involved violated a state’s vehicle code, or if their negligence (carelessness) may have caused the accident. Police reports will also contain the contact information (name and phone number) of anyone involved in the accident, or witnesses of the accident. In some situations, the report may also contain witness statements about the accident, which may be valuable when trying to prove liability (fault).
If you were involved in an accident where a police report was created, you are entitled to receive a copy of the report. If you know the agency that created the report, find their contact information (phone book or Internet) and call them to request a copy of your report. Some agencies make you pick up the report in person and pay a small processing fee. Other agencies will send you the report at no charge.
What should I do if I think the accident is partially my fault?
Generally, the time after you have been involved in an automobile accident can often be stressful or confusing, and despite your honorable intentions, you may not be in the best position to figure out why or how the accident happened. Admitting fault (even partial fault) may be used against you later.
There are countless possible causes of an accident. However, if you believe that you are partially to blame for the accident you should contact an experienced attorney that will be able to provide guidance and advise you of your options.
Is a lawsuit always necessary?
A personal injury claim and a personal injury lawsuit are separate and distinct from one another.
A personal injury claim does not involve an attorney, and is between the victim and the at-fault driver’s insurance company before a lawsuit has been filed. In a personal injury claim, if you are injured in an accident (personal injury or property damage) caused by the other driver, you would pursue the at-fault driver, who would turn the matter over to their insurance agency. The insurance agency would then assign a claims adjuster who will contact the victim, and through a series of negotiations, work toward a settlement. However, claims adjusters are professional negotiators with extensive experience and may ask questions in a manner that may hurt your claim.
A personal injury lawsuit, on the other hand, may be filed at any time after the accident. Except, if the victim has already been speaking with the claims adjuster, a lawsuit generally begins when the victim and the claims adjuster cannot reach an agreement and the victim contacts an attorney.
However, not all personal injury disputes that are handled by attorneys result in a lawsuit being filed. The attorney may draft a demand letter, which presents facts about the accident in order to persuade the insurance company to provide adequate compensation. The demand letter is sent to the insurance company with supplemental documents, which the insurance company will analyze and then respond with its settlement offer.
Generally, if you have been injured in an automobile accident you should speak to an attorney as soon as possible. An experienced attorney will be able to provide guidance before you speak with the at-fault’s insurance agency and give legal advice if you have questions about the settlement value of an insurance claim, the terms of your insurance policy, or if you suspect bad faith on the part of your insurance company.
If I file a lawsuit will I have to go to court?
The majority of legal claims arising from accidents do not reach a civil trial; therefore, the parties never go before a jury. They are typically resolved earlier in the litigation process through a negotiated settlement between the parties. There are many reasons why parties may decide to settle, including trial expense, stress, privacy and excess length of time. The decision to settle ultimately belongs to the client, although the client’s attorney will typically advise the client as to the pros and cons of accepting the settlement.
However, if the opposing party is unwilling to negotiate, or the plaintiff (injured person) will not receive sufficient compensation to cover their damages, a case will proceed to trial and the parties will go to court. Having an experienced attorney, that was well prepared to go to court from the outset, will maximize the likelihood of a successful outcome in trial.
If I am involved in a car accident in Illinois, how long do I have to file a lawsuit for personal injuries?
In civil law there are time limits in which a plaintiff (injured person) must file a civil claim or be forever barred from doing so. These time limits are called statutes of limitations.
In Illinois, a lawsuit for personal injuries must be filed within two years of the date of the accident (or within two years after the cause of action accrued) or it will be barred. 735 Ill. Comp. Stat. 5/13-202. If the plaintiff is under the age of 18, or is under legal disability at the time of the accident, they must bring the civil claim within two years after the person turns 18, or the disability is removed. 735 Ill. Comp. Stat. 5/13-211(a).
Under the Local Governmental and Governmental Employees Tort Immunity Act, a lawsuit against a local entity or its employees for any injury must be filed within one year of the date of the incident. 745 Ill. Comp. Stat. 10/8-101(a). In Illinois, a lawsuit for property damage must be filed within five years of the date of the accident. 735 Ill. Comp. Stat. 5/13-205.
It is best to contact a car accident attorney who has experience with Illinois law in order to accurately determine the appropriate statute of limitations for your specific situation.
How long do I have to notify an opposing party that I am filing a claim for personal injuries related to an automobile accident?
If you are planning to file a personal injury lawsuit against an individual, there is no specific set time that you need to notify that individual. However, you should be aware that Illinois employs a two-year statute of limitations for personal injury lawsuits, 735 Ill. Comp. Stat. 5/13-202 and if you do not comply, you will be barred from recovery.
In Illinois, how long will it take to settle an automobile accident case involving personal injuries?
The length of time it will take to settle an automobile accident depends on many factors and will vary from case to case. Such factors include: the question of liability, the significance of the injuries involved and the recovery period for those injuries. Additionally, the length of time will be directly related to the insurance company.
Many personal injury cases can be settled between the victim and the at-fault driver’s insurance company through a claims adjuster. The victim and claims adjuster work through a series of negotiations to reach a settlement. The settlement may be reached within a matter of weeks of the accident; however, claims adjusters are skilled negotiators and tend to propose a low-ball offer. Because a settlement waives your rights to future claims arising from the accident, it is not recommended to accept a settlement from an insurance company until you have fully recovered from your injuries so that you know the extent of your medical expenses.
Generally, if you have been injured in an automobile accident you should speak to an attorney as soon as possible. Working with an attorney may take several months to negotiate a settlement; however, an experienced attorney will be able to provide guidance before you speak with the at-fault’s insurance agency and give legal advice if you have questions about the settlement value of an insurance claim.
In certain circumstances, an Illinois automobile accident cannot be resolved by a settlement because the opposing party is unwilling to negotiate, or the plaintiff (injured person) will not receive sufficient compensation to cover their damages, and a lawsuit must be filed. A lawsuit gives the plaintiff time to depose witnesses and assess the extent of their injuries. However, the majority of automobile accidents settle before going to trial. If your case goes to trial, having an experienced attorney, that was well prepared to go to court from the outset, will maximize the likelihood of a successful outcome.
Is car insurance mandatory for drivers in Illinois?
Yes, under Illinois law all drivers are required to carry liability coverage insurance. 625 Ill. Comp. Stat. 5/7-601(a). Drivers must carry liability coverage of at least $25,000 per person for injury or death, at least $50,000 for injury or death of two or more people, and at least $20,000 for property damage of another. 625 Ill. Comp. Stat. 5/7-203. A driver that fails to comply with these laws may have their license plates suspended. 625 Ill. Comp. Stat. 5/7-601.
Illinois also requires that drivers obtain uninsured motorist coverage with limits that are equal to your bodily injury liability coverage ($25,000); however, this does not cover property damage. 215 Ill. Comp. Stat. 5/143a. Uninsured motorist coverage will help cover injuries to you or your passengers if you are involved in an accident with an uninsured driver.
What if I was in a car accident and the person who caused the accident does not have insurance?
Illinois law requires that drivers obtain uninsured and hit and run motorist coverage with limits that are equal to your bodily injury liability coverage ($25,000); however, this does not cover property damage. 215 Ill. Comp. Stat. 5/143a. Your uninsured motorist coverage will help cover injuries to you or your passengers if you are involved in an accident with an uninsured driver.
Additionally, if you end up with a judgment against the at-fault driver, Illinois law states you may have the Secretary of State suspend the at-fault driver’s license, registration certificate and license plates until the judgment has been paid. 625 Ill. Comp. Stat. 5/7-303(a). You may also be able to go after the driver’s wages or savings to pay off the judgment.
What do I do if the insurance company denies my claim for medical expenses or property damage?
Insurance companies have many reasons why they would deny or pay a claim. One of the most common reasons is if the insurance company disputes the liability (fault) of their insured driver. Because Illinois law employs the doctrine of modified comparative fault, the plaintiff (injured person) will be compared to other parties in the accident, and if the plaintiff’s fault is less than 50% they may recover damages (in proportion to the amount of fault attributable to the plaintiff). 735 Ill. Comp. Stat. 5/2-1116(c). However, if the plaintiff’s contribution of fault to the accident is more than 50% they will be barred from recovery. 735 Ill. Comp. Stat. 5/2-1116(c).
An example of this is when a plaintiff and a defendant get in an automobile accident, and the plaintiff sustains injuries costing $100,000. Nevertheless, it is found that the plaintiff was 70% at fault for the accident. In this case, the plaintiff would not be able to recover from the defendant or their insurance company. On the other hand, if the plaintiff was only 30% at fault for the accident, the plaintiff may recover $70,000 for their injuries ($100,000 minus their 30% fault) because they are less than 50% at fault.
Other reasons that insurance companies may deny claims are: the company believes the injuries you sustained in the accident were prior injuries, the police report does not indicate you had any complaints of pain, the insurance company was not promptly notified of the accident, and the at-fault party does not have enough coverage to pay for the damages (partial denial).
Denial of an insurance claim is common. In order to know if your claim was properly denied, it is best to consult an experienced Illinois attorney. An attorney will assist you in determining whether there was an unreasonable denial of the claim, or unreasonable delay by the insurance company in settling the claim, in which, the insurance company may be held liable. 215 Ill. Comp. Stat. 5/155(1). Additionally, if the insurance company refuses to settle and bad faith is found, punitive damages may be awarded.
What does it mean when a driver I was involved in an accident with has ‘full coverage?’
While there are many automobile insurance options one may chose, there is really no such thing as a ‘full coverage’ catchall. When people speak about full automobile coverage they are generally stating that they have liability coverage, property coverage and uninsured coverage.
However, this may not mean that the driver is adequately insured. For example, Illinois law states that all drivers are required to carry liability coverage insurance of certain minimum amounts. 625 Ill. Comp. Stat. 5/7-601(a). Drivers must carry liability coverage of at least $25,000 per person for injury or death, at least $50,000 for injury or death of two or more people, and at least $20,000 for property damage of another. 625 Ill. Comp. Stat. 5/7-203. In some cases the minimum amount of coverage may not be adequate to cover all the expenses of the accident.
It is important to contact an experienced Illinois automobile accident injury attorney to evaluate your specific case.
Why does my insurance have to pay for the injuries I sustained when another person caused the accident?
Despite Illinois’ mandatory automobile liability coverage, there continue to be people that drive uninsured. Additionally, most uninsured drivers have no assets to collect in order to satisfy your damages claim.
Illinois’ requirements that drivers obtain uninsured motorist coverage with limits that are equal to your bodily injury liability coverage ($25,000) 215 Ill. Comp. Stat. 5/143a helps cover injuries to you or your passengers if you are involved in an accident with an uninsured driver.
Should I notify my insurance company of an accident?
Yes. You have a duty to cooperate with your own insurance company after an automobile accident. Most insurance companies require their policyholders to report an automobile accident and give the basic facts. However, limit your conversation with the insurance company to discussing the facts. Never admit liability (fault) or make accusations.
Before speaking with your insurance company contact an experienced motor vehicle accident attorney who will be able to provide guidance and give legal advice if you have questions about the settlement value of an insurance claim, the terms of your insurance policy, or if you suspect insincerity on the part of your insurance company.
Do I need to give a statement to the opposing party’s insurance company if they contact me?
No, you are in no way obligated to speak with the opposing party’s insurance company. Politely decline to speak with them and give them your attorney’s name and contact information.
It has become common practice for insurance companies to contact parties involved in an automobile accident shortly after it has occurred. It may seem harmless; however, claims adjusters are professional negotiators with extensive experience and may ask questions in a manner that may be bad for your claim.
How much does it cost to hire a Chicago automobile injury attorney?
Generally, personal injury attorneys do not charge a fee for the initial consultation or the review of the facts that surround your case. Personal injury attorneys usually work on a contingency fee basis, where the attorney agrees to accept a fixed percentage of the recovery for the client in the form of a settlement or a jury verdict. If you lose the case, neither you nor your attorney will get compensation. However, even if you lose, the client will have to pay court-filing fees, costs related to deposing a witness and other similar charges.
The Lamber-Goodnow Injury Law Team assists clients on a contingency fee basis, which means our lawyers only get paid when and if we secure a favorable settlement or verdict. Let us help you accurately evaluate the value of your case and make the most informed decision for your specific situation.
If I have injuries resulting from a car accident how soon after the accident should I get an attorney?
If you have injuries resulting from an automobile accident you should speak with an attorney as soon as possible. Many times facts become hazy, witnesses move, and insurance company’s adjusters ask questions in a manner that may hurt your claim. An experienced attorney will be able to analyze the information you have gathered, provide guidance and advise you whether you have a viable personal injury claim.
When I meet with an attorney what should I expect?
During the first meeting with your attorney after an automobile accident, the attorney will want to know what happened, and they may want to collect a variety of information from you. The length of the meeting will vary from case to case and will depend on the complexities of your specific situation.
During the meeting, the attorney will ask you to tell them about the accident and your resulting injuries. Make sure to share with the attorney all relevant information about your accident and injuries. Even if you do not end up hiring the attorney, the information will be subject to attorney-client privilege, so it is very important to be honest. Allow the attorney to decide whether the information is, or is not, in your favor. It is better for the attorney to know all relevant information upfront, instead of having to find out information that may hinder your case later.
The attorney will collect a variety of information relating to your accident and injury, including contact information of other people involved in the accident, witnesses to the accident, medical treatments you have received, police reports, photos of the injury or of the accident scene, information about your insurance coverage or if you have spoken to a claims adjuster, and any other relevant information. Additionally, your attorney will likely discuss the practical aspects of your case, including different costs to expect, fee agreements and a representation agreement.
Following the initial meeting, the attorney may need time to consider your case; this is a common occurrence and should not cause undue worry. If the attorney agrees to represent you, they may ask you to sign an agreement for representation. Make sure to read the agreement and ask the attorney any questions you may have. The attorney should explain the agreement in detail and allow you to take it home to review before signing. Additionally, if the attorney agrees to represent you, they will probably tell you what the next steps will entail, as well as how they will keep you informed of the progress in your case.
An attorney may also decline to take your case. There are many reasons that this may occur, including the attorney’s large caseload, their specialties, their family situation, or you may find that in their opinion you do not have much of a case. If this occurs they may refer you to another attorney.
I feel fine, should I still go see a doctor after my automobile accident?
Yes, you should always seek medical attention after being involved in an automobile accident. Injuries sustained in an automobile accident may not be noticeable until days, or even weeks, after an accident. Even if you feel fine it is important for a medical professional to check and make sure that you have no internal injuries. When you meet the doctor, make sure to communicate any injury you may have, no matter how minor. Seeing a medical professional is important to begin immediate treatment, as well as to document your injuries from the automobile accident.
In Illinois what type of monetary damages does the law provide for automobile accident cases?
There are several types of damages that a person may claim in a personal injury lawsuit involving an automobile accident in Illinois. The Illinois Supreme Court has stated that the primary goal of an award of damages in a tort case is to compensate the plaintiff (injured person) for his or her injuries.
The Illinois Pattern Jury Instructions give eleven major categories in which a plaintiff may claim damages. These categories include: “(1) the nature and extent of the injuries; (2) the expected duration of the injuries; (3) the aggravation of pre-existing ailment or condition; (4) disfigurement; (5) disability or loss of a normal life; (6) pain and suffering, past and future; (7) emotional distress, past and future; (8) the expense of necessary medical care, past and future, (9) the value of time, earnings, profits, and salaries lost, past and future; (10) the cost of caretaking expenses, past and future; and (11) the plaintiff’s age and any shortened life expectancy.”
Additionally, when a third party injures one spouse, the other spouse has an action against that third party for damages. This action is called loss of consortium. A loss of consortium includes loss of marital support (the injured spouse is unable to financially support or contribute), and loss of companionship and sexual relationship.
A plaintiff is also entitled to the reasonable expense of necessary repairs to damaged property. Moreover, a plaintiff may claim punitive damages in Illinois in cases where the acts were particularly egregious. The purpose of punitive damages is to punish the defendant and to deter them and others from committing the same or similar acts in the future.
Furthermore, Illinois follows the collateral source rule, which prevents a jury from hearing that a plaintiff may have insurance benefits, social security benefits, workers’ compensation benefits or pension benefits. This prevents the jury from learning anything about a collateral benefit that might affect its judgment on the amount of damages given to the plaintiff.
If I was injured in an automobile accident and unable to work for several months, may I recover my lost wages in Illinois?
Yes. After an automobile accident, injuries may cause you to lose your earning capacity. This may include time spent in the hospital, time spent at physical therapy, problems with mobility, or circumstances where a person is so significantly injured they are unable to return to their employment.
In Illinois, a plaintiff (injured person) may recover compensatory damages if they are injured in an automobile accident. Compensatory damages compensate the plaintiff for his or her past or future losses caused by the defendant’s actions. Compensatory damages may include past and future lost earnings, and profits or salaries that they would have received while working. This may also include sick time, and vacation time.
If I’m a passenger in an automobile, can I make a claim against the driver of the car in which I was riding, or the other driver?
Yes. Even if you were a passenger in the liable (at-fault) party’s car, you may still file a claim for personal injuries against the driver. Additionally, if the accident was not the fault of the driver of the car in which you are a passenger, you may file a personal injury claim against the other at-fault driver. The insurance company of the at-fault driver will be liable for your losses, whether you are a passenger in a car or the driver.
If a company owned the automobile that caused my personal injuries, is the company responsible for paying my personal injuries?
Sometimes. In certain cases an employer may be liable for the negligent operation of the automobile by an employee under a theory called respondeat superior. If the employer owned the automobile, and the employee was at the time of the accident engaged in doing the owner’s business, the employer could be liable for the personal injuries of the plaintiff (injured person).
The importance of an employer’s liability is that most corporate insurance policies include several layers of coverage and may be more substantial than an individual’s insurance policy. Depending on the extent of your personal injuries, an employer’s policy may adequately cover your injuries, where a personal policy may not.
My husband was driving the automobile and caused an accident while my son was a passenger. Can I pursue a claim on behalf of my son—against my husband?
Yes. If a husband is negligent and caused his son’s personal injuries, a mother may sue her husband on behalf of her son. 750 Ill. Comp. Stat. 65-1. If the husband caused the son’s personal injuries, the son has the same right to recover as a person that is not related. The son may file a lawsuit against the father if he is 18, however, if the son is a minor, his mother, or a court appointed guardian, (“guardian ad litem”) must bring the case.
If the son is under the age of 18, or is under legal disability at the time of the accident, he must bring the civil claim within two years after he turns 18, or the disability is removed. 735 Ill. Comp. Stat. 5/13-211(a).
Our No-Fee Promise
When you first speak with us, there’s no charge for an initial consultation. We’ll go over your case, make an evaluation and a recommendation. If you choose to hire us, you won’t pay any charges or fees for our services – unless and until we recover a settlement or a judgment in your favor. We call it our No-Fee Promise, and we stand by it.
Talk to us Today
Call us at (312) 757-777 at any time, day or night to set up an initial consultation with one of the members of our car accident legal team. Before you talk to anyone from an auto insurance company, make sure you talk to an attorney – put your interests ahead of theirs.
 O’Neill v. Gallant Ins. Co., 329 Ill.App.3d 1166, 769 N.E.2d 100 (5th Dist. 2002).
 Wilson v. The Hoffman Group, Inc., 131 Ill. 2d 308, 137 Ill. Dec. 579, 546 N.E.2d 524 (1989).
 Illinois Pattern Jury Instructions (Civil) Nos. 30.02-30.09.
 Illinois Pattern Jury Instructions (Civil) Nos. 32.04.
 Illinois Pattern Jury Instructions (Civil) Nos. 30.13.
 Slovinski v. Swanson Dev. Co. LLC, 2014, IL App (3d) 110784, 378 Ill. Dec. 889, 5 N.E.3d 279.
 Baston v. Oak Tree, Ltd., 2013 IL App (1st) 123071, 377 Ill. Dec. 489, 2 N.E.3d 405.
 Chow v. Aegis Mortgage Corp., 185 F. Supp. 2d 914, 918 (N.D. Ill. 2002).
 Illinois Pattern Jury Instructions (Civil) Nos. 30.02-30.09
 Ritter v. Taucher (1978, 1st Dist.) 65 Ill App 3d 464, 22 Ill Dec 23, 382 NE2d 343.