Difference Between ''Some Evidence'' Standard and ''Reasonably Certain Proof''
In LaFever v. Kemlite Co., 185 Ill. 2d 380, 406-07, 235 Ill. Dec. 886, 706 N.E.2d 441 (1998), the supreme court distinguished between the "some evidence" standard that entitles a plaintiff to a jury instruction on an element of future damages and the "reasonably certain proof" standard that represents the quantum of proof plaintiff needs to prevail on his damage claim. LaFever, 185 Ill. 2d at 407.
The court noted:
"Plaintiff need only furnish 'some evidence' probative of his claim to earn a jury instruction on that claim, and neither the trial court nor a court of review must be convinced of the persuasiveness of that evidence before the issue may be submitted to the jury for its deliberations." LaFever, 185 Ill. 2d at 407.