Illinois Court of Appeals
675 N.E.2d 249 (1996)
Laura Green’s (plaintiff) son, Calvin, was transported to the hospital for a bullet wound. While he was undergoing emergency treatment, staffers from the Chicago Tribune Company (Chicago Tribune) (defendant) photographed Calvin without Green’s consent. After attempts to revive Calvin failed, medical personnel moved him to a private hospital room to await the coroner. Around that time, a Chicago Tribune reporter asked Green for a statement regarding her son’s death. Green declined. Simultaneously, Chicago Tribune staffers entered Calvin’s private room and took more photographs of him. When Green protested and demanded to enter the room, the staffers prevented her doing so. Once Green finally gained access to Calvin’s room, she spoke softly to her son. However, Chicago Tribune staffers overheard Green’s statements and published them, as well as the photographs of her deceased son in the newspaper. A subsequent article showing Green’s son undergoing emergency treatment did not feature Green in any manner. Green filed suit against the Chicago Tribune and its employees (defendants) for two counts of intentional infliction of emotional distress (IIED). The trial court dismissed Green’s complaint. Green appealed.
Rule of Law
Holding and Reasoning (O’Brien, J.)
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