To Get Contribution, Name That Tortfeasor!

A tortfeasor settling with a claimant under Section 2(c) of the Contribution Act, 740 ILCS 100/2(c), is not entitled to recover contribution from another tortfeasor whose liability is not extinguished by the settlement, 740 ILCS 100/2(d). The lesson: name any joint tortfeasors who are potential sources of contribution in the release. Guerrero v. Sebastian Contracting Corp., 321 Ill.App.3d 32, 746 N.E.2d 846, 254 Ill.Dec. 89 (1st Dist. 2001).