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One Is Not Enough

An Illinois First District opinion recently ruled that citation to just one case did not prevent waiver of an argument of unjust enrichment. The court stated there was a failure to discuss the relevancy of the case. The failure to cite relevant authority was a violation of Illinois SCR 341, and the argument therefore was waived. The whole case is here, Fortech LLC v. R.W. Duntemann Co., 852 N.E.2d 541, No. 1-05-1526 (2006).

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