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before this court meets that standard. See Johnson, 203 Ill. 2d at 136, 784 N.E.2d at 822 (“[t]he fact

that the [circuit] court did not conduct an evidentiary hearing *** does not mean that [it] did not

consider whether the settlement amount bore a reasonable relationship to the settling party’s relative

culpability”). Thus, in light of all the information before the circuit court, we hold that the circuit

court did not abuse its discretion in making a good-faith finding.

Finally, we reject the U-Haul entities’ contention that our supreme court’s decision in Ready

changed the landscape regarding how courts determine whether a settlement agreement was made

in good faith. The U-Haul entities argue that courts must now engage in a heightened level of

scrutiny of the settlement agreement before making a good-faith finding because “Ready provides

an incentive for plaintiffs, like Cellini, to settle with more culpable defendants, like Buffalo Grove,”

while leaving “deep pocket” defendants, such as the U-Haul entities, “exposed to paying a majority

of a potential judgment.” They argue that this would result in unfairness to the U-Haul entities

because Buffalo Grove was the “primary wrongdoer.”

In Ready, the decedent’s wife sued decedent’s employer, a general contractor and a

subcontractor as a result of a fatal construction site accident that occurred during the lifting of

wooden trusses from the ground floor to the eighth floor of a power plant. Ready, 232 Ill. 2d at 371-

72, 905 N.E.2d at 727. The decedent’s wife reached settlement agreements totaling $1.113 million

with the general contractor and the employer. Ready, 232 Ill. 2d at 372, 905 N.E.2d at 727. The

subcontractor did not object. Ready, 232 Ill. 2d at 372, 905 N.E.2d at 727. Subsequently, the circuit

court found that the settlement agreements were made in good faith. Ready, 232 Ill. 2d at 372, 905

N.E.2d at 727-28. As a result of the parties’ motions in limine, the circuit court ruled that the


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