Illinois Supreme Court
Andrews v. Carbon on 26th, LLC
May 22, 20252025 IL 130862
Summary
The court held that a buyer may satisfy the UCC notice requirement through the seller's actual knowledge of the defect in the particular product and transactions, even when that knowledge arose from personal-injury lawsuits brought by other parties. The wholesalers had actual knowledge that the specific cilantro shipments sold to the distributor were allegedly contaminated and linked to the outbreak, so summary judgment based on lack of direct notice was improper. The appellate court's judgment was affirmed, and the cause was remanded for further proceedings.