First American Bank v. Northampton Group Ltd.

CourtDistrict Court, N.D. Illinois
DecidedMay 14, 2025
Docket1:23-cv-01168
StatusUnknown

This text of First American Bank v. Northampton Group Ltd. (First American Bank v. Northampton Group Ltd.) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
First American Bank v. Northampton Group Ltd., (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

FIRST AMERICAN BANK,

Plaintiff and Counter-Defendant, No. 23 CV 1168 v. Judge Manish S. Shah NORTHAMPTON GROUP LTD.,

Defendant and Counter-Plaintiff.

MEMORANDUM OPINION AND ORDER

This dispute arises from years-long litigation in state court over a condominium property that was plagued by water leaks. That litigation finally concluded with First American Bank, who sold the property to Northampton Group, prevailing over the condominium association’s claims for fraud and breach of fiduciary duty. While that case remained pending on appeal, the Bank brought suit in this court against Northampton seeking indemnification for the costs of defending the state-court lawsuit. Northampton brings a counterclaim against the Bank for breach of contract, and the Bank moves for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). For the reasons discussed below, that motion is granted. I. Legal Standard Federal Rule of Civil Procedure 12(c) permits any party to move for judgment on the pleadings after the pleadings are closed. Fed. R. Civ. P. 12(c). A party can move under Rule 12(c) “to dispose of the case on the basis of the underlying substantive merits” or to raise a Rule 12(b) defense. Wolf v. Riverport Ins. Co., 132 F.4th 515, 518 (7th Cir. 2025) (quoting Alexander v. City of Chicago, 994 F.2d 333, 336 (7th Cir. 1993)). When a moving party challenges the sufficiency of a complaint under Rule 12(c), the same plausibility standard under Rule 12(b)(6) applies. Id. at 518–19. When

ruling on a Rule 12(c) motion, I may consider the pleadings, any exhibits attached to the complaint, and matters of public record that are not subject to reasonable dispute. See id. and South Branch LLC v. Commonwealth Edison Co., 46 F.4th 646, 648 (7th Cir. 2022). II. Background I assume familiarity with the earlier order denying Northampton’s motion to dismiss. See First Am. Bank v. Northampton Grp. Ltd., No. 23-CV-1168, 2024 WL

1302788 (N.D. Ill. Mar. 27, 2024). First American Bank sold the Fountain Square on the River Condominiums to Northampton Group in 2014. [1] ¶ 11.1 Three years later, the Fountain Square on the River Condominium Association brought claims for fraud and breach of fiduciary duty against the Bank, several of its board members, the developer, and the general contractor in the Circuit Court of Kane County. [52-2]. The Bank filed a third-party complaint against Northampton seeking indemnification

under the contract for sale. [25-1]. The trial court dismissed the Bank’s complaint without prejudice, to be maintained until “the whole thing is final.” [17-2] at 17. The

1 Bracketed numbers refer to entries on the district court docket. Referenced page numbers are taken from the CM/ECF header placed at the top of filings. This court has jurisdiction because First American Bank, as trustee, and First American Bank are citizens of Illinois, Northampton Group is a citizen of Canada, and the amount in controversy exceeds $75,000. [1] ¶¶ 3–7, 26–27; 28 U.S.C. § 1332(a). The parties apply Illinois law. See generally [52], [60], [61]; Paulsen v. Abbott Lab’ys, 39 F.4th 473, 477 (7th Cir. 2022) (citations omitted). For sake of simplicity, I refer to First American Bank as one entity. [1] ¶¶ 3–4. state court ultimately dismissed the underlying fraud claims with prejudice, [1-3], and the Association appealed the judgment, [17-3]. The litigation in this court concerns the Bank’s breach of contract claim against

Northampton to enforce the indemnification clause. [1]. After I denied Northampton’s motion to dismiss, Northampton answered the complaint and filed a counterclaim for breach of contract against the Bank. [32]. Northampton alleges that the Bank breached the contract for sale by failing to disclose information related to defects that caused the water leaks. [32] ¶¶ 117–29. Northampton alleges that Bank-appointed members of the Condominium Association “facilitated the adoption of assessments

and reserves they knew (or should have known) would be inadequate” and “knowingly enabled [the Bank] to present financial statements on the rental operations… which contained no provision for major work to permanently correct the causes of the water infiltration problems.” [32] ¶ 117. These financial statements and the failure to disclose “latent defects” induced Northampton to purchase condominium units at a higher price. [32] ¶ 118. Northampton alleges that the Bank was obligated to disclose certain documents containing information related to: (1) defects; (2) “the Bank’s band-

aid approach to correcting the defects”; (3) constructions reports; or (4) “anticipated costs of properly correcting the causes of the water filtration problems.” [32] ¶ 118. Northampton requested “structural and engineering reports” as part of its due diligence process but only received an engineering report from a third-party firm dated December 22, 2009, indicating that “to the best of [the firm’s] knowledge, all active leaks have been addressed.” [32] ¶ 122. Northampton claims that the Bank failed to disclose at least eight other engineering reports (all predating the December 22, 2009 report) dealing with leakage issues; the Bank and its board members were the only people with knowledge of “latent defects” and the information in those third-

party reports; and the Bank concealed these reports to induce Northampton’s purchase. [32] ¶ 120–23. After attempting settlement, the parties requested a stay of the proceedings pending the outcome of the appeal. [46]. I granted the stay. [47]. The appellate court has since affirmed the trial court’s dismissal of the condominium association’s claims for fraud and breach of fiduciary duty against the Bank, and the Illinois Supreme

Court denied the Association’s petition for leave to appeal. See Fountain Square on the River Condo. Ass’n, Ltd. v. First Am. Bank, 2024 IL App (2d) 230076-U, appeal denied, No. 131333, 2025 WL 951934 (Ill. Mar. 26, 2025). III. Analysis First American Bank argues that the doctrine of res judicata bars Northampton’s counterclaim for breach of contract. [52] at 5, 15–18. In the alternative, the Bank argues that (1) Northampton’s breach of contract counterclaim

rests on allegations of fraud and concealment that do not satisfy Rule 9(b)’s pleading requirements and (2) specific terms in the contract for sale preclude reliance on any representations or omissions by the Bank. [52] at 6, 9–15. Illinois law applies. See Allen v. McCurry, 449 U.S. 90, 96 (1980). I am required to give the same preclusive effect to a state court judgment as any Illinois court rendering judgment would grant it. 28 U.S.C. § 1738; Matsushita Elec. Indus. Co. v. Epstein, 516 U.S. 367, 373 (1996). Claim preclusion, or res judicata, promotes judicial economy by barring “multiple lawsuits between the same parties where the facts and issues are the same.” Lutkauskas v. Ricker, 2015 IL 117090, ¶ 44; River Park, Inc. v. City of Highland Park, 184 Ill.2d 290, 319 (1998). Claim preclusion requires: (1) a

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