Macleod v. Commonwealth Edison

Plaintiff filed a lawsuit against the defendants after they entered into a deferred prosecution agreement in a matter where the defendants allegedly paid bribes to a former speaker of the Illinois House. Plaintiff asserted a claim for equitable accounting and a violation of the Consumer Fraud and Deceptive Business Practices Act. The trial court dismissed the complaint with prejudice for failure to state a claim and plaintiff appealed. The appellate court affirmed finding, among other things, that the plaintiff had failed to establish proximate cause between the passage of relevant legislation and the alleged payment of bribes. (McLAREN and MULLEN, concurring)