Vision Point of Sale, Inc. v. Haas

In Vision Point of Sale, Inc. v. Haas, 226 Ill. 2d 334, 875 N.E.2d 1065, 314 Ill. Dec. 778 (2007), our supreme court overruled an interpretation of Rule 216 that imposed a signature requirement not created by the rule's plain language, and held that denials certified in accordance with section 1-109 of the Code of Civil Procedure are sufficient to satisfy the rule's requirement of service of a sworn statement. As the majority notes, Rule 216 provides that facts that are the subject of admission requests are deemed admitted unless "the party to whom the request is directed serves upon the party requesting the admission a sworn statement denying specifically the matters of which admission is requested or setting forth in detail the reasons why he cannot truthfully admit or deny those matters." 134 Ill. 2d R. 216. The rule's language requires only "a" sworn statement, not "the party's statement," not "his statement," and not "her statement." The rule addresses the actions of an answering party only in requiring her to serve the responses upon her opponent. Like the signature requirement imposed by this court in Moy and disapproved by the supreme court in Vision Point, the majority's mandate that the sworn statement be made by the party "has no support in the language of Rule 216." Vision Point, 226 Ill. 2d at 355.