Lubbers v. Norfolk & Western

In Lubbers v. Norfolk & Western (1986), 147 Ill. App. 3d 501, 498 N.E.2d 357, 101 Ill. Dec. 175, where admissibility of subsequent repairs to a train crossing signal was at issue, the court also stated that evidence of subsequent repairs or improvements is inadmissible to show defendant's negligence, but such evidence may be used for proving ownership, feasibility of precautionary measures, or impeachment. In that case, the court found that the plaintiff simply stated that the evidence would have been admissible to show defendant's notice of the problem and the feasibility of making repairs; however, the plaintiff failed to show how these matters relate to any of the issues involved in that case. Lubbers, 147 Ill. App. 3d at 515.