RulesofCivilProcedure.com Civil Procedure · Every State

2-1201.Return of verdict - Separate counts - Defective or unproved counts.

Article II. Civil Practice · Part 12. Post-Trial · Not amended since adoption on record · Last verified July 20, 2026

In one sentenceSection 2-1201 explains how a jury delivers its verdict, when the court enters judgment on it, and when a defective or unproven theory can still leave a verdict standing.

Full Text of 735 ILCS 5/2-1201

Text size

(a) It is sufficient for the jury to pronounce its verdict by its foreman in open court, without reducing it to writing, if it is a general verdict. The clerk shall enter it in form, under the direction of the court. (b) Promptly upon the return of a verdict, the court shall enter judgment thereon. (c) If there are several counts in a complaint, counterclaim or third-party complaint based on different claims upon which separate recoveries might be had, the court shall, on the motion of any party, direct the jury to find a separate verdict upon each claim. (d) If several grounds of recovery are pleaded in support of the same claim, whether in the same or different counts, an entire verdict rendered for that claim shall not be set aside or reversed for the reason that any ground is defective, if one or more of the grounds is sufficient to sustain the verdict; nor shall the verdict be set aside or reversed for the reason that the evidence in support of any ground is insufficient to sustain a recovery thereon, unless before the case was submitted to the jury a motion was made to withdraw that ground from the jury on account of insufficient evidence and it appears that the denial of the motion was prejudicial.

Plain-English Summary

This section starts with the mechanics of a verdict: a general verdict doesn't need to be written out. The foreperson announces it in open court, the clerk enters it, and the court promptly enters judgment on it.

When a complaint, counterclaim, or third-party complaint bundles several counts that rest on different claims capable of separate recovery, any party can ask the court to make the jury return a separate verdict on each one, rather than one lump verdict covering everything.

The section then protects a verdict from being undone just because one of several theories behind it was weak. If a claim rested on more than one ground and at least one ground holds up, the verdict survives even if another ground was defective or under-proven. The one exception: a party who moved, before the case went to the jury, to strike the weak ground for lack of evidence, and can show the denial of that motion caused prejudice.

Frequently Asked Questions

Does a jury have to put its verdict in writing under Illinois law?

No. For a general verdict, the foreperson pronounces it in open court and the clerk enters it in form under the court's direction.

What happens right after the jury returns its verdict?

The court promptly enters judgment on the verdict.

Can I force the jury to return a separate verdict on each claim in a multi-count case?

Yes. When counts rest on different claims that could support separate recoveries, any party can move the court to direct separate verdicts on each one.

Will a verdict get thrown out if one of several legal theories behind it was weak?

Not automatically. If at least one ground is sufficient to sustain the verdict, it stands, even if another ground was defective or unsupported by the evidence.

What if a party wanted a weak ground pulled from the jury before it deliberated?

If that party moved to withdraw the ground for insufficient evidence before submission, and the denial of that motion was prejudicial, the verdict can still be set aside on that basis.

Amendment History

(Source: P.A. 83-707.)

Source & verification. Section text and amendment history are reproduced verbatim from the Illinois Compiled Statutes, published by the Illinois Compiled Statutes, Illinois General Assembly / Legislative Reference Bureau. Last verified July 20, 2026. · Official source
Also known as: illinois general verdict rulejury verdict entry illinoisseparate verdict each count illinoisdefective count verdict illinoismultiple grounds recovery verdict illinois