an action to obtain compensation for a wrong against the plaintiff, when the situation did not fit the technical requirements for an action of Trespass. Trespass on the Case applied where the injury to the plaintiff was indirect rather than direct, where it was accidental with no force, where the property was not in the plaintiff’s possession, or where the property was intangible. Trespass on the Case applied to the misfeasance (wrong performance) of a Contract but not to nonfeasance (doing nothing). It also applied to cases of Slander or Libel. Clerks and lawyers frequently referred to the action as simply “Case.” The distinction between Trespass and Trespass on the Case was very fine and technical; in 1872, the Illinois legislature abolished the distinction.