Dent v. Constellation NewEnergy, Inc.

Summary

The Illinois Supreme Court held that a court may consider a qualified-privilege defense on a section 2-615 motion when the defense appears on the face of a Rule 224 petition and its exhibits. Because the alleged statements arose from an investigation of workplace sexual-harassment allegations, the privilege applied to all three unidentified speakers, and the petition's conclusory assertion that the statements were false did not allege abuse of the privilege. The court therefore reversed the appellate court and reinstated dismissal of the petition with prejudice.