Create a legal Memo for the following cases:

1. Coe v. Lewsader, 64 N.E.3d 817
2. King v. Ohren, 198 Ill. App. 3d 1098
3. Partipilo v. DiMaria, 211 Ill. App. 3d 813

Include heading, question presented, brief answer, facts section, discussion (issue, rule, analysis, & conclusion), overall conclusion.