Jacobs v. Northwestern Memorial Hospital

2025 IL App (1st) 241325-U
CourtAppellate Court of Illinois
DecidedNovember 12, 2025
Docket1-24-1325
StatusUnpublished

This text of 2025 IL App (1st) 241325-U (Jacobs v. Northwestern Memorial Hospital) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jacobs v. Northwestern Memorial Hospital, 2025 IL App (1st) 241325-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 241325-U No. 1-24-1325 Order filed November 12, 2025 Second Division

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________ IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________ ERIKA JACOBS, ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Cook County. ) v. ) No. 23 M1 300950 ) NORTHWESTERN MEMORIAL HOSPITAL, ) Honorable ) Maryam Ahmad, Defendant-Appellee. ) Judge, presiding.

PRESIDING JUSTICE VAN TINE delivered the judgment of the court. Justices McBride and Ellis concurred in the judgment.

ORDER

¶1 Held: We affirm the dismissal of plaintiff’s medical malpractice claim due to her failure to comply with section 2-622 of the Code of Civil Procedure. Pursuant to section 2-615, we affirm the dismissal of plaintiff’s claim that defendant hospital should have “waived” all medical billing, as she has not pled a legally cognizable claim.

¶2 Plaintiff Erika Jacobs appeals from the dismissal of her pro se second amended complaint

against defendant Northwestern Memorial Hospital (Northwestern). The circuit court dismissed

plaintiff’s complaint pursuant to sections 2-603(b) and 2-622 of the Code of Civil Procedure (the No. 1-24-1325

Code) because plaintiff failed to (1) format her complaint as numbered paragraphs with separate

counts for each claim and (2) support her medical malpractice claim with a medical professional’s

report concluding that claim was reasonable and meritorious. See 735 ILCS 5/2-603(b), 2-622

(West 2022). For the following reasons, we affirm.

¶3 I. BACKGROUND

¶4 This appeal involves two sections of the Code that govern pleadings, which we set out here

for context. Section 2-603(b) requires that, in a complaint, “[e]ach separate cause of action upon

which a separate recovery might be had shall be stated in a separate count,” “each count *** shall

be separately pleaded, designated and numbered,” and the complaint “shall be divided into

paragraphs numbered consecutively, each paragraph containing, as nearly as may be, a separate

allegation.” 735 ILCS 5/2-603(b) (West 2022). Section 2-622 generally requires that a plaintiff

alleging medical malpractice support her complaint with “(1) an affidavit, her attorney’s or her

own if proceeding pro se, certifying that the affiant consulted with a qualified health care

professional in whose opinion there is a reasonable and meritorious cause for the filing of the

action,” and “(2) a copy of that health professional’s written report setting forth the reasons for his

[or her] determination.” Schroeder v. Northwest Community Hospital, 371 Ill. App. 3d 584, 595

(2009); 735 ILCS 5/2-622(a)(1) (West 2022).

¶5 Plaintiff has proceeded pro se throughout this entire case, including this appeal. She used

preprinted forms for all her complaints in the circuit court, filled them out by hand, and attached

various typewritten statements and exhibits to them.

¶6 The record on appeal does not contain reports of proceedings. We take the following facts

from the common law record.

-2- No. 1-24-1325

¶7 A. Original Complaint

¶8 On July 17, 2023, plaintiff filed a small claims complaint alleging that she received

treatment for an open wound on her left knee at Northwestern’s emergency room on July 19, 2022.

Plaintiff alleged that emergency room doctors did not properly culture or clean her wound and did

not give her a knee brace. The emergency room doctors’ negligence allegedly caused plaintiff’s

left leg to “crack” in September 2022.

¶9 Although plaintiff alleged facts regarding medical malpractice, her complaint stated that

her claim was based only on Northwestern’s failure to process “financial information” and “waive”

$2,726.50 that Northwestern billed her. Plaintiff attached to her complaint her own typewritten

statement, which claimed that Northwestern “put [her] in collections for the disputed amount of

$2,726.50.” Plaintiff further explained that

“[t]his lawsuit is about the malicious behavior of the hospital staff in the

non[-]processing of the Plaintiff’s financial application for 100% waiver based on the

financial status; amount disputed $2,726.50. Now the medical Mal practice [sic] would be

a separate case in another court for a sum I cannot even compute.”

Plaintiff also attached medical bills from Northwestern reflecting that the hospital charged her

$3,895 for treatment on July 19, 2022, but reduced those charges by $1,168.50 due to adjustments

and insurance payments. Northwestern ultimately billed plaintiff $2,726.50.

¶ 10 Northwestern moved to dismiss plaintiff’s complaint. Without ruling on the motion to

dismiss, the Honorable John M. Allegretti granted plaintiff leave to amend her complaint by

October 18, 2023.

-3- No. 1-24-1325

¶ 11 Nevertheless, plaintiff filed motions seeking Judge Allegretti’s “removal” and a transfer to

the law division. Plaintiff claimed that Judge Allegretti did “not respect [her] as a person of interest

in the case” and would not give her a fair trial. Plaintiff also claimed that her amended complaint

would seek damages of $1 million for medical malpractice, necessitating a transfer to the law

division. Judge Allegretti denied plaintiff’s request to transfer the case to the law division but

granted her request for substitution of judge as of right.

¶ 12 The case was transferred to the Honorable Thomas Morrissey. Although Judge Morrissey

issued several orders in this case, the docket report suggests that the Honorable Maryam Ahmad

may have presided over some hearings between December 2023 and June 2024. Judge Ahmad

may have been covering Judge Morrissey’s call on those dates, or the case may have been

reassigned to her at some point. The record is not clear on that issue. There is no question, however,

that Judge Ahmad entered the final order in this case.

¶ 13 B. First Amended Complaint

¶ 14 On October 13, 2023, plaintiff filed her first amended complaint pursuant to Judge

Allegretti’s order. Plaintiff explained that her original complaint had alleged “improper processing

of [her] financial information for 100% waiver of fees,” but the first amended complaint raised a

claim of medical malpractice. Plaintiff alleged that she was unable to use her left leg when she

arrived at Northwestern’s emergency room on July 19, 2023. 1 The treating physician did not

properly clean or culture the wound, did not provide plaintiff with antibiotics or pain medication,

1 The original complaint alleged that plaintiff was treated at Northwestern on July 19, 2022, but the first amended complaint alleged that she was treated on July 19, 2023. That may have been a typographical error. Plaintiff’s brief on appeal claims that she went to Northwestern in July 2022. Northwestern medical bills attached to the original complaint confirm that plaintiff was treated on July 19, 2022.

-4- No. 1-24-1325

and did not provide a brace to stabilize plaintiff’s left leg. In addition, plaintiff alleged that a

physical therapist did not examine her and the physical therapy assistant who did examine her was

not qualified to diagnose her.

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Bluebook (online)
2025 IL App (1st) 241325-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jacobs-v-northwestern-memorial-hospital-illappct-2025.