Pfaff v. Chrysler Corp

In Pfaff v. Chrysler Corp., 155 Ill. 2d 35, 610 N.E.2d 51, 182 Ill. Dec. 627 (1992), the Illinois Supreme Court set forth the general standard governing the granting of injunctions against foreign litigation: "The trial court has the authority to restrain the prosecution of a foreign action which will result in fraud or gross wrong or oppression; a clear equity must be presented requiring the interposition of the court to prevent manifest wrong and injustice. What constitutes a wrong and injustice requiring the court's interposition must necessarily depend upon the particular facts of the case. There is no general rule as to what circumstance constitutes a proper case for the exercise of the trial court's discretion. The granting of an injunction will depend on specific circumstances as to whether equitable considerations in favor of granting the injunction outweigh the legal right of the party who instituted the foreign action." Pfaff, 155 Ill. 2d at 58, 610 N.E.2d at 61.