Gardner v. Navistar International Transportation Corp.

This case involves an appeal from the trial court’s granting of summary judgment, necessitating that we reexamine the evidentiary foundations required before summary judgment is entered. As part of this reexamination, we will analyze Supreme Court Rule 191 (134 Ill. 2d R. 191), dealing with affidavits submitted in support of motions for summary judgment.

I. Background

In October 1980, Homer Gardner (Gardner) was operating his Oliver model 88 tractor to pick corn in his fields. An explosion occurred on the tractor, and Gardner was seriously burned. He died from his injuries eight days later.

In…