In a recent Illinois case, a plaintiff identified as Doe sued her ex-boyfriend, Jones, for secretly videotaping their sexual encounters. She also sued some of Jones's friends for soliciting and distributing the videos. The court permitted these claims to proceed.

However, Doe's additional claims against Jones's parents, who owned the home where some recordings took place, were rejected. The court found no evidence that the parents engaged in conduct that could be considered extreme or outrageous. The only alleged conduct was that Jennifer, one of the parents, expressed her devastation and disappointment over her son's actions to Doe, which the court ruled "is not a tort."

Doe's assertion that the parents "knew or should have known" about their son's tortious conduct lacked factual support. Although Jones Sr. is a police officer, the court held that this did not establish liability. The homeowners argued they owed no duty to Doe simply because their adult son, without their knowledge, harmed her in their home.

Regarding premises liability, the court noted that under the Illinois Premises Liability Act, owners owe a duty to entrants on their property, typically requiring proof of duty, breach, and injury proximately caused by the breach. Since Doe's injuries were emotional rather than physical, the court found no basis for liability.

Doe may file an amended complaint addressing the court's identified deficiencies by August 24, 2026.

The court emphasized that "suing individuals because they have a homeowner's insurance policy or are collectible defendants is not a proper purpose for a lawsuit."

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