Doe v. Doe, 67 N.E.3d 520

Decedent (Jane Doe II) committed suicide on June 10, 2013. Plaintiff, as special administrator of the estate, sued two minors (John Doe II and Jane Doe IV) and their parents for negligence and negligent supervision, alleging online communications encouraging or falsely stating intent to self-harm precipitated the suicide.
Plaintiff alleged John Doe II fraudulently represented on social media that he intended to commit suicide or harm himself; Jane Doe IV repeated/communicated those statements knowing they were false.
Plaintiff asserted the minors’ communications and the parents’ failure to monitor social media caused the decedent severe emotional distress leading to suicide; six counts were filed (negligence against minors and negligent supervision against parents).
Defendants moved to dismiss under 735 ILCS 5/2-615, arguing the decedent’s suicide was an independent intervening act that broke the chain of causation; the trial court granted dismissal with prejudice for all counts and denied leave to amend.
Plaintiff sought reconsideration and leave to amend (asserting she could add that John Doe II knew the decedent was suicidal and encouraged her), but did not tender a proposed amended complaint or specify the factual additions; motions were denied.
The appellate court reviews a 2-615 dismissal de novo and examines whether the complaint pleaded facts showing the suicide was a foreseeable, not merely a factual, result of defendants’ conduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether suicide was a foreseeable proximate result of defendants’ conduct	Plaintiff: alleged communications caused severe anguish and were a foreseeable cause of suicide	Defendants: suicide was a voluntary, independent intervening act breaking causation	Held: Suicide was unforeseeable as a matter of law; dismissal affirmed
Whether complaint sufficiently pleaded facts (not conclusions) that suicide was foreseeable	Plaintiff: pleadings alleged foreseeability and could be amended to add that John Doe II knew decedent was suicidal and encouraged her	Defendants: complaint contained only conclusory statements lacking supporting factual allegations	Held: Conclusions unsupported by facts insufficient; dismissal proper
Whether negligent-supervision claims alleged parents had notice of risk	Plaintiff: parents failed to monitor and allowed minors’ communications	Defendants: no allegations of prior specific conduct putting parents on notice	Held: Plaintiff failed to allege prior instances or notice; supervision claims deficient
Whether trial court abused discretion by denying leave to amend	Plaintiff: could allege that John Doe II knowingly encouraged suicide	Defendants: plaintiff never provided proposed amendment or specific facts; no recognized exception to suicide rule alleged	Held: Denial not abuse of discretion; proposed facts (as asserted) still would not invoke exceptions to the suicide rule

Turcios v. DeBruler Co., 2015 IL 117962 (suicide is an independent intervening act unforeseeable as matter of law)
Kanerva v. Weems, 2014 IL 115811 (standard of review for 2-615 dismissal)
Boyd v. Travelers Ins. Co., 166 Ill. 2d 188 (elements of negligence claim)
Jarvis v. South Oak Dodge, Inc., 201 Ill. 2d 81 (court will not accept conclusions of fact or law unsupported by pleaded facts)
Lott v. Strang, 312 Ill. App. 3d 521 (parental notice requirement for negligent supervision)