Federal National Mortgage Ass'n v. Reynolds

2024 IL App (1st) 231665-U
CourtAppellate Court of Illinois
DecidedOctober 17, 2024
Docket1-23-1665
StatusUnpublished
Cited by1 cases

This text of 2024 IL App (1st) 231665-U (Federal National Mortgage Ass'n v. Reynolds) 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
Federal National Mortgage Ass'n v. Reynolds, 2024 IL App (1st) 231665-U (Ill. Ct. App. 2024).

Opinion

2024 IL App (1st) 231665-U Order filed: October 17, 2024

FIRST DISTRICT FOURTH DIVISION

No. 1-23-1665

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT ______________________________________________________________________________

FEDERAL NATIONAL MORTGAGE ) Appeal from the ASSOCIATION, ) Circuit Court of ) Cook County. Plaintiff-Appellee, ) ) No. 22 M 1713457 v. ) ) Honorable ANY AND ALL UNKNOWN OCCUPANTS and ) Barry Goldberg, LINDA REYNOLDS, ) Judge, presiding. ) Defendants ) ) (Linda Reynolds, ) ) Intervenor and Defendant-Appellant). ) ______________________________________________________________________________

PRESIDING JUSTICE ROCHFORD delivered the judgment of the court. Justices Hoffman and Ocasio concurred in the judgment.

ORDER

¶1 Held: Order denying defendant’s motion to dismiss and awarding summary judgment in favor of plaintiff is affirmed, where affidavit and documents relied upon by defendant failed to comply with Illinois Supreme Court Rule 191(a), and defendant forfeited any argument as to the merits of her posttrial motions.

¶2 In this eviction action, intervenor and defendant-appellant, Linda Reynolds, appeals from

the denial of her motion to dismiss and the grant of summary judgment in favor of plaintiff-

appellee, Federal National Mortgage Association (Federal). For the following reasons, we affirm. No. 1-23-1665

¶3 Federal initiated this lawsuit on August 30, 2022, by filing a complaint against “Any and

All Unknown Occupants” of a residential property in Dolton, Illinois, pursuant to the Eviction Act

(formerly the Forcible Entry and Detainer Act). 735 ILCS 5/9-101, et seq. (West 2022). Therein,

Federal sought possession of the property after the unknown occupants unlawfully “held over after

Mortgage Foreclosure.” Attached to the complaint were several exhibits, including: (1) a

September 26, 2019, foreclosure sale deed awarding title of the property to Federal, following a

July 23, 2019, judicial sale resulting from a prior foreclosure action, and (2) a notice, dated May

11, 2022, to any and all unknown occupants of the property of Federal’s intent to file an eviction

action and a demand for possession of the property, effective 90 days after the proper service of

the notice.

¶4 The record contains two affidavits of service. The first indicates that after four prior

unsuccessful attempts, service of Federal’s notice of intent to file an eviction action and demand

for possession of the property was completed on May 24, 2022, by posting the notice and

documents on the door of the property and by sending them via certified mail. The second indicates

that after two prior unsuccessful attempts, substitute service of the summons and complaint was

completed at the property on January 21, 2023, upon a member of the household, Cynthia Smith.

Notably, Cynthia Smith was one of the named defendants in the prior foreclosure action. Status

orders entered on April 3, 2023, and May 1, 2023, indicate that Smith was present in court on those

days, and this matter was continued for trial to May 23, 2023.

¶5 On that day, Reynolds, acting pro se, filed a petition seeking leave to intervene and file an

appearance in this lawsuit. Therein, she asserted that she “has a bona-fide lease, bona fide tenant

[sic] that is current with paid rent receipts and can provide facts concerning this cause of action.

Petitioner has contractual and monetary interest.” She therefore sought leave to intervene and file

-2- No. 1-23-1665

her appearance to protect her rights “on terms prescribed by the court.” Attached to the petition

was a copy of a purported lease agreement for the property between Reynolds and the “Griot

Group. LLC.” The lease agreement indicated that the original date of the lease was April 1, 2018,

and that the renewal term of the lease was to run from April 1, 2020, to March 31, 2024. It was

dated April 1, 2020, and the monthly rent was $950.

¶6 On May 31, 2023, the circuit court entered an order granting Reynolds leave to intervene,

conditioned however by section 408(f) of the Code of Civil Procedure (Code) (735 ILCS 5/2-

408(f) (West 2022)), which provides that: “An intervenor shall have all the rights of an original

party, except that the court may in its order allowing intervention, whether discretionary or a matter

of right, provide that the applicant shall be bound by orders or judgments, theretofore entered or

by evidence theretofore received, that the applicant shall not raise issues which might more

properly have been raised at an earlier stage of the proceeding, that the applicant shall not raise

new issues or add new parties, or that in other respects the applicant shall not interfere with the

control of the litigation, as justice and the avoidance of undue delay may require.” As such, the

circuit court specifically noted that Reynolds’ request for a jury trial would not be permitted.

¶7 On June 14, 2023, Reynolds filed a motion to strike and dismiss Federal’s complaint,

pursuant to section 2-619(a)(9) of the Code. 735 ILCS 5/2-619(a)(9) (West 2022). Therein, she

asserted that she had a current bona-fide lease for the property, had not been made a party to the

prior foreclosure action, had never been properly personally served with either the foreclosure

complaint or Federal’s notice of intent to file an eviction action and demand for possession of the

property in this matter, and had not been properly served via any other means. As such, Reynolds

asserted that the complaint in this matter should be stricken and dismissed due to Federal’s failure

to comply with the service and jurisdictional requirements of sections 9-104 and 15-1508.5 of the

-3- No. 1-23-1665

Code (735 ILCS 5/9-104, 15-1508.5 (West 2022), or the Protecting Tenants at Foreclosure Act of

2009, P.L. 111–22, § 702(a)(2)(A), 123 Stat. 1632, 1662 (2009). Attached as exhibits in support

of the motion were Reynolds’ own affidavit, a copy of the purported lease for the property, a

receipt for payment of rent for May and June of 2023, and her appearance and jury demand.

¶8 Federal filed a combined response to the motion to dismiss and motion for summary

judgment. Therein, Federal generally asserted that the affidavit and documents Reynolds filed in

support of her motion to dismiss failed to comply with the requirements of Illinois Supreme Court

Rule 191 (eff. Jan. 4, 2013), that she had therefore provided no admissible evidence of her rights

as a tenant, and therefore Federal had fully complied with the relevant service and jurisdictional

requirements with respect to unknown occupants of the property. As such, Federal asked the circuit

court to deny the motion to dismiss and grant summary judgment in its favor. Attached in support

were, inter alia, the order approving the sale in the prior foreclosure action which also granted

Federal possession of the property, a recorded and notarized judicial sale deed awarding title of

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2024 IL App (1st) 231665-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/federal-national-mortgage-assn-v-reynolds-illappct-2024.