Lewis v. Kalbhen

Illinois Appellate Court
Civil Court
Litigation Privilege
Citation
Case Number: 
2025 IL App (1st) 242110
Decision Date: 
Wednesday, December 10, 2025
District: 
1st Dist.
Division/County: 
3d Div./Cook Co.
Holding: 
Affirmed.
Justice: 
ROCHFORD

Plaintiff filed a lawsuit alleging that defendants committed multiple privacy torts against her in the course of conducting a background investigation of her on behalf of her former husband during divorce proceedings. The circuit court entered summary judgment in favor of the defendants, finding that the complained-of conduct, which included photographing and checking a license plate, was protected by the absolute litigation privilege. The appellate court agreed and affirmed. (LAMPKIN and REYES, concurring)