Dawkins v. Fitness International, LLC

Summary

The Illinois Supreme Court affirmed the appellate court’s reversal, holding that the Facility Preparedness Act and the AED Act impose a statutory duty on fitness facilities to refrain from willful and wanton non‑use of an AED, creating a private right of action; consequently, the plaintiff’s willful‑and‑wanton claims survive the motion to dismiss and the case is remanded for further proceedings.