Is a Foreign Corporation Doing Business In a State Under License Authorised by Law Subject to Attachment As a Non-Resident ?
In Charles Friend & Co. v. Goldsmith & Seidel Co., 307 Ill. 45, 48, 138 N.E. 185, 186 (1923), the supreme court considered the dismissal of an attachment suit in which the issue on appeal was "whether a foreign corporation doing business in this State under the license authorized by law is subject to attachment as a non resident."
As a part of the discussion of that issue, the supreme court noted that a corporate entity may be considered a person but not a citizen. Charles Friend & Co., 307 Ill. at 50, 138 N.E. at 187.
However, that discussion in Charles Friend & Co. does not apply to the issue of standing under section 11-301.
Later cases have limited the scope of the Charles Friend & Co. case to the particular statute at issue therein. See LeBlanc v. G.D. Searle & Co., 178 Ill. App. 3d 236, 240, 533 N.E.2d 41, 43, 127 Ill. Dec. 423 (1988) (the Charles Friend & Co. case was only decided "in light of the purpose of the attachment statute").