Judge Leibenweber of the Northern District of Illinois held that Illinois has jurisdiction over an out-of-state defendant in the matter Rusinowski v. DiDomenico where the out-of-state resident, Didomenico, related to an intentional infliction of emotional distress claim where the defendant made a police report that the plaintiff was homicidal and suicidal causing the plaintiff to be arrested at his home and placed in a mental institution for five days against his will.