Doe v. Doe

Illinois Appellate Court
Civil Court
Proximate Cause
Citation
Case Number: 
2016 IL App (1st) 153272
Decision Date: 
Thursday, November 10, 2016
District: 
1st Dist.
Division/County: 
Cook Co., 6th Div.
Holding: 
Affirmed.
Justice: 
HOFFMAN

Mother of minor who committed suicide sued parents of another minor who had, over social media, fraudulently expressed to decedent his intention to commit suicide or inflict severe physical harm upon himself; Plaintiff alleged that parents were negligent in failing to monitor their son's conversations over social media. Court properly dismissed complaint per Section 2-615, finding that, as a matter of law, the decedent minor's suicide was an independent intervening cause which broke chain of causation between their alleged negligence and the decedent's death. Under the "suicide rule", based on principles of proximate cause, the injury suffered by a plaintiff must be the natural consequence, not merely a remote consequence, of the defendant's act for a recovery in tort. Complaint did not contain factual allegations that decedent's suicide was foreseeable result of Defendants' conduct. (CUNNINGHAM and DELORT, concurring.)