Cleeton v. SIU Healthcare, Inc.

Summary

The court held that the plaintiff presented sufficient pleadings and documentary evidence to establish probable cause for converting the physician from a respondent in discovery to a defendant under section 2-402. The statute requires only a low threshold: evidence creating an honest and strong suspicion that the respondent's negligence proximately caused the injury, not proof of liability or a prima facie case. The court reversed both lower-court judgments and remanded for further proceedings.