Bowman v. The Chicago Park District

2014 IL App (1st) 132122, 19 N.E.3d 75
CourtAppellate Court of Illinois
DecidedSeptember 5, 2014
Docket1-13-2122
StatusUnpublished
Cited by3 cases

This text of 2014 IL App (1st) 132122 (Bowman v. The Chicago Park District) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bowman v. The Chicago Park District, 2014 IL App (1st) 132122, 19 N.E.3d 75 (Ill. Ct. App. 2014).

Opinion

2014 IL App (1st) 132122 No. 1-13-2122 Fifth Division September 5, 2014

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

ARTENIA BOWMAN, Individually and as ) Appeal from the Circuit Court Mother and Next Friend of Cheneka Ross, a ) of Cook County. Minor, ) ) Plaintiff-Appellant, ) ) No. 11 L 7865 v. ) ) THE CHICAGO PARK DISTRICT, a Municipal ) Corporation, ) The Honorable ) Kathy M. Flanagan, Defendant-Appellee. ) Judge Presiding.

JUSTICE GORDON delivered the judgment of the court, with opinion. Presiding Justice Palmer and Justice Taylor concurred in the judgment and opinion.

OPINION

¶1 Plaintiff Artenia Bowman, individually and as mother and next friend of Cheneka Ross, a

minor, filed suit in the circuit court of Cook County against the Chicago Park District (CPD)

alleging willful and wanton conduct for failing, for almost a year, to repair a damaged slide.

Plaintiff’s daughter, Cheneka Ross, age 13, was going down a slide on April 21, 2011, when

her foot became caught in a hole in the plastic at the bottom of the slide, resulting in a

fractured ankle. Defendant CPD owns the property and maintains the playground equipment,

including the slide. No. 1-13-2122

¶2 Defendant filed a motion for summary judgment (735 ILCS 5/2-1005 (West 2010))

claiming: (1) that it did not owe any duty to Cheneka because she was not an intended user of

the slide since she was 13 years old and the slide was intended for children aged under 12;

and (2) that the hole at the bottom of the curved slide was an open and obvious risk that the

13-year-old should have avoided. Plaintiff, in her response to defendant’s motion for

summary judgment, claims: (1) that defendant failed to establish as a matter of law that CPD

had designated the park and the slide for only children under 12 years old; (2) that the danger

created by the hole at the bottom of the curved slide was not open and obvious; and (3) that

CPD’s failure to repair the slide, after being informed almost a year earlier of the danger,

constituted willful and wanton conduct.

¶3 The trial court granted defendant’s motion for summary judgment, finding that 13-year-

old Cheneka had violated a CPD ordinance by using a slide that had been designed for

children under 12 years old, although there were no signs to indicate an age limit. Since the

trial court found that Cheneka was not an intended user of the slide, it did not discuss

whether the damage was open and obvious or whether CPD’s failure to repair the slide was

willful and wanton conduct.

¶4 On this direct appeal, plaintiff argues: (1) that the trial court erred by granting defendant

summary judgment on the basis that 13-year-old Cheneka was not an intended user of

defendant’s slide; (2) that the danger created by the hole at the bottom of the curved slide

was not open and obvious; and (3) that CPD’s failure to repair the slide, after being informed

of its condition almost a year earlier, constituted willful and wanton conduct.

¶5 For the following reasons, we find the trial court erred in granting summary judgment on

the basis that Cheneka was not the intended user of the slide and reverse. We remand for the

2 No. 1-13-2122

trial court to decide whether the slide’s condition was open and obvious and whether CPD’s

failure to repair the slide after being notified was willful and wanton conduct.

¶6 BACKGROUND

¶7 I. The Complaint

¶8 The complaint at issue on this appeal is plaintiff’s second amended complaint, which was

filed on March 1, 2012. The suit seeks damages for injuries sustained by plaintiff’s daughter,

Cheneka, when she damaged her ankle on a park slide on April 21, 2011. The complaint

alleges that Cheneka was using the slide when her foot came in contact with a hole that

caused a fracture in her ankle; and that defendant CPD was aware that the slide was

dangerous and had failed to repair it. Count I alleges defendant acted willfully and wantonly

toward users of the slide by failing to repair the slide even though it had received numerous

complaints from the community. Count II sought recovery on behalf of her daughter’s

medical expenses under the Rights of Married Persons Act, commonly known as the Family

Expense Act. 750 ILCS 65/15 (West 2010).

¶9 II. Defendant’s Motion for Summary Judgment

¶ 10 On January 13, 2013, defendant, as noted, filed a motion for summary judgment,

claiming: (1) that it did not owe any duty to Cheneka because she was not an intended user of

the slide; and (2) that the slide was an open and obvious risk that the 13-year-old should have

avoided.

¶ 11 CPD argued that it had an ordinance stating that children age 12 and older should not use

playground equipment designed for children under the age of 12. CPD claims that, since

Cheneka was 13 years old, she violated the ordinance, and CPD was immune from liability.

3 No. 1-13-2122

¶ 12 CPD also claimed that the danger at the bottom of the curved slide was open and obvious,

and that the 13-year-old should not have used the slide because a reasonable child would

have avoided it. CPD also claimed that, since the 13-year-old was unsupervised, she should

be old enough to appreciate obvious risks; however, issues of supervision were not raised on

appeal.

¶ 13 Plaintiff responded to the motion contending that defendant had failed to establish that

the 13-year-old was not the intended user of the slide. She claimed that the park was open to

the public and no sign was present in the park prohibiting children age 12 and older from

using the slide. Plaintiff also contended that the hole at the bottom of the curved slide was not

open and obvious because she was unable to see the hole prior to being injured. The slide

was curved, which made it difficult for children to observe what was in front of them.

¶ 14 III. Exhibits

¶ 15 A. Cheneka Ross’s Deposition

¶ 16 Cheneka testified in a discovery deposition that, on April 21, 2011, she went with friends

to a park located at 1420 North Artesian Avenue1 to play a game of tag. Most of her friends

were several years younger than her, including her brother. It was around 7 p.m. and starting

to become dark. She had played at this park before and had been there several times. While

playing tag, Cheneka ran to the slide to avoid being tagged by one of her friends. She went

up the slide and when she descended, her foot became caught in a hole in the plastic, at the

bottom of the slide, causing a fractured ankle requiring surgery.

¶ 17 Cheneka testified that she did not observe the hole at the bottom of the slide before her

foot became caught. She did not observe the crack from the top of the slide and identified a

1 The parties agree that the park is known as Park 399.

4 No. 1-13-2122

photograph of the slide. The photograph, which was introduced at the deposition, showed

that the slide was curved, and the top of the slide did not line up with the bottom.

¶ 18 B. Artenia Bowman’s Affidavit and Deposition

¶ 19 Artenia Bowman is Cheneka’s mother. In an affidavit attached to plaintiff’s response to

the motion for summary judgment, Cheneka’s mother alleges that there were no signs posted

which designated the age group for the playground. Specifically, there were no signs stating

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2014 IL App (1st) 132122, 19 N.E.3d 75, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bowman-v-the-chicago-park-district-illappct-2014.