The Illinois Supreme Court affirmed a defense verdict in a medical malpractice case against Quincy Medical Group, rejecting plaintiff Robert Schilling's claims that trial court errors warranted a new trial. The unanimous decision, filed Jan. 23, 2026, represents the conclusion of a lengthy legal battle that began with allegations of medical negligence in the treatment of a diabetic patient.
Schilling filed a two-count medical malpractice complaint against Dr. Kreg J. Love and his employer, Quincy Physicians & Surgeons Clinic, S.C., doing business as Quincy Medical Group. The case centered on medical care Schilling received on Jan. 12, 2017, when he visited QMC as a type 1 diabetic patient seeking treatment related to his diabetes condition.
Following a jury trial in the circuit court of Adams County, the jury returned a verdict in favor of the defendants. However, Schilling appealed the decision, raising two primary arguments challenging the trial court's handling of jury procedures during deliberations.
The plaintiff's first argument focused on the trial court's response to a note received from one of the jurors during deliberations. Schilling contended that the trial court abused its discretion by failing to declare a mistrial after receiving this juror communication. The specific contents and nature of the juror's note were not detailed in the Supreme Court's opinion, but the court found that the trial judge acted within proper discretion in handling the situation.
Schilling's second argument challenged the trial court's polling of the jury. Jury polling is a standard procedure that allows the court to confirm that each juror agrees with the verdict as announced. Schilling argued that the trial court's conduct during this polling process was improper and constituted an abuse of discretion that warranted reversal of the verdict.
The case first went to the Appellate Court, Fourth District, which affirmed the trial court's judgment in a 2024 decision. The appellate court found no merit in Schilling's arguments and upheld both the trial court's handling of the juror note and its jury polling procedures. This appellate decision set the stage for Schilling's further appeal to the state's highest court.
Justice Rochford delivered the Supreme Court's opinion, with Chief Justice Neville and Justices Theis, Overstreet, Holder White, Cunningham, and O'Brien all concurring. The unanimous nature of the decision suggests the court found Schilling's arguments unpersuasive and saw clear support for the lower courts' handling of the case.
The Supreme Court's brief opinion focused specifically on the procedural issues raised by Schilling rather than the underlying medical malpractice claims. This approach reflects the narrow scope of the appeal, which did not challenge the sufficiency of evidence or the jury's factual determinations, but rather the trial court's management of jury-related procedures.
Medical malpractice cases in Illinois, as in other states, require plaintiffs to prove that healthcare providers breached the standard of care and that this breach caused injury. The fact that this case reached the Supreme Court on procedural rather than substantive grounds suggests that the underlying malpractice claims may have been weak or that the evidence did not support Schilling's allegations against Dr. Love and QMC.
The court's affirmance of the defense verdict means that Schilling will not receive compensation for his claimed injuries. For healthcare providers, the decision reinforces that trial courts have significant discretion in managing jury procedures and that appellate courts will not easily second-guess these decisions absent clear abuse of discretion.
This case also highlights the importance of proper jury management during medical malpractice trials. Trial judges must balance transparency with the need to maintain jury integrity when communications arise during deliberations. The Supreme Court's approval of the trial court's handling suggests that judges have latitude in addressing such situations as long as they act reasonably.
For future medical malpractice litigation in Illinois, this decision provides guidance on the standards appellate courts will apply when reviewing trial court decisions about jury polling and responses to juror communications. The unanimous nature of the Supreme Court's affirmance indicates that these standards are well-established and that successful challenges to such trial court decisions will require clear evidence of abuse of discretion.
The decision concludes a case that began nearly nine years ago with Schilling's 2017 medical treatment, demonstrating the lengthy timeline that complex medical malpractice litigation can involve as cases move through trial and multiple levels of appeal.
