Palos Community Hospital v. Humana Insurance Co., Inc.

2021 IL 126008

IN THE SUPREME COURT OF THE STATE OF ILLINOIS (Docket No. 126008) PALOS COMMUNITY HOSPITAL, Appellant, v. HUMANA INSURANCE COMPANY, INC., Appellee. Opinion filed May 20, 2021. JUSTICE THEIS delivered the judgment of the court, with opinion. Chief Justice Anne M. Burke and Justices Garman, Michael J. Burke, Overstreet, and Carter concurred in the judgment and opinion. Justice Neville took no part in the decision. OPINION ¶1 At issue is whether the “test the waters” doctrine constitutes a valid basis on which to deny a party’s motion for substitution of judge as of right under…