Forsythe v. Clark USA, Inc

In Forsythe v. Clark USA, Inc., 224 Ill. 2d 274, 864 N.E.2d 227, 309 Ill. Dec. 361 (2007), the relationship was established where the parent company directly participated in the wrongdoing of its subsidiary, which proximately caused the plaintiffs' decedents' deaths. Forsythe, 224 Ill. 2d at 290. The court then cited the four factors that "inform" this inquiry: (1) the reasonable foreseeability of injury; (2) the likelihood of injury; (3) the magnitude of the burden of guarding against the injury; (4) the consequences of placing the burden upon the defendant. Forsythe, 224 Ill. 2d at 290-91.