Spadoni v. United Airlines, Inc.

4 Citing cases

  1. Landale Signs & Neon, Ltd. v. Runnion Equip. Co.

    274 F. Supp. 3d 787 (N.D. Ill. 2017)   Cited 9 times

    Defendant's argument that Plaintiff has failed to "state a cause of action for breach of an implied duty of good faith and fair dealing," [35] at 4, is a non-sequitur—no such cause of action exists under Illinois law. See Spadoni v. United Airlines, Inc. , 400 Ill.Dec. 187, 47 N.E.3d 1152, 1165 (Ill. App. Ct. 2015) ("Illinois law does not recognize an independent cause of action for breach of implied duty of good faith and fair dealing in a contract."). Instead, the Court must determine whether Plaintiff has competently alleged a breach of the parties' contract, and the implied duty of good faith and fair dealing simply serves as "a construction aid in determining the intent of the parties where an instrument is susceptible of two conflicting constructions." Id.

  2. VC Mgmt., LLC v. Reliastar Life Ins. Co.

    195 F. Supp. 3d 974 (N.D. Ill. 2016)   Cited 5 times
    Applying Illinois law

    Here, ReliaStar's good faith and fair dealing defense is not related to ambiguities in the language of the Policy. Rather, ReliaStar asserts that VCM had an independent duty to act in good faith solely based on the fact that a contract existed between the parties. Such an independent duty of good faith and fair dealing does not appear to exist under Illinois law. SeeSpadoni v. United Airlines, Inc. , 2015 IL App (1st) 150458, 400 Ill.Dec. 187, 47 N.E.3d 1152, 1165 (Ill.App.Ct. 1st Dist.2015) ( "Illinois law does not recognize an independent cause of action for breach of an implied duty of good faith and fair dealing in a contract.") Further, the court is not persuaded that VCM's failure to disclose Baker's death promptly constitutes bad faith.

  3. Traffic Tech, Inc. v. Arts Transp., Inc.

    No. 15 C 8014 (N.D. Ill. Apr. 1, 2016)   Cited 9 times

    The court does note however, that under Illinois law, the covenant of good faith and fair dealing is not a basis for an independent cause of action. Spadoni v. United Airlines, Inc., 2015 IL App (1st) 150458, ¶ 59. Thus, to the extent that Arts seeks to pierce a claim premised on that covenant it would not be a recognized cause of action under Illinois law.

  4. Eckhardt v. The Idea Factory, LLC

    2021 Ill. App. 210813 (Ill. App. Ct. 2021)   Cited 18 times

    But, unless unconscionable, an adhesive contract term is generally enforceable against the adhered-to party if within their reasonable expectations. Spadoni v. United Airlines, Inc., 2015 IL App (1st) 150458, ¶ 50 (Harris, J., dissenting); Lane v. Francis Capital Management LLC, 168 Cal.Rptr.3d 800, 810-11 (Ct. App. 2014). Likewise, "contracts are interpreted objectively and must be construed in accordance with the ordinary expectations of reasonable people."