Ford City Condominium Ass'n v. Wilmington Savings Fund Society

2020 IL App (1st) 190112-U
CourtAppellate Court of Illinois
DecidedJanuary 28, 2020
Docket1-19-0112
StatusUnpublished

This text of 2020 IL App (1st) 190112-U (Ford City Condominium Ass'n v. Wilmington Savings Fund Society) 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
Ford City Condominium Ass'n v. Wilmington Savings Fund Society, 2020 IL App (1st) 190112-U (Ill. Ct. App. 2020).

Opinion

2020 IL App (1st) 190112-U No. 1-19-0112

SECOND DIVISION January 28, 2020

NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule 23(e)(1). ____________________________________________________________________________

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT ____________________________________________________________________________

FORD CITY CONDOMINIUM ASSOCIATION, ) Appeal from the Circuit Court ) of Cook County. Plaintiff-Appellee, ) ) v. ) No. 17 M1 715310 ) WILMINGTON SAVINGS FUND SOCIETY ) FSB DBA CHRISTIANA TRUST, not in its ) The Honorable individual capacity but solely as trustee for BCAT ) Joel Chupack, 2015-14BTT, U.S. BANK TRUST NATIONAL ) Judge Presiding. ASSOCIATION, as trustee of AMERICAN ) HOMEOWNER PRESERVATION TRUST ) SERIES 2015A+, and ANY UNKNOWN ) OCCUPANTS, ) ) Defendants ) ) (U.S. Bank Trust National Association, as trustee ) of American Homeowner Preservation Trust Series ) 2015A+, Defendant-Appellant). ) ) ____________________________________________________________________________

JUSTICE PUCINSKI delivered the judgment of the court. Justices Lavin and Coghlan concurred in the judgment. 1-19-0112

ORDER

¶1 Held: Where the foreclosure purchaser’s payment of post-sale common expenses was not made promptly, it did not serve to extinguish the condominium association’s lien on the unit for unpaid pre-sale common expenses under section 9(g)(3) of the Condominium Property Act (765 ILCS 605/9(g)(3) (West 2016)). In addition, the trial court did not abuse its discretion in awarding the condominium association attorney’s fees.

¶2 In this eviction proceeding, defendant U.S. Bank Trust National Association, as trustee of

American Homeowner Preservation Trust Series 2015A+ (“U.S. Bank”), appeals from the trial

court’s judgment in favor of plaintiff, Ford City Condominium Association (“Ford City”) on its

claim for past-due assessments and other fees and costs. Defendant also appeals from the trial

court’s award of attorney’s fees to Ford City. For the reasons that follow, we affirm.

¶3 BACKGROUND

¶4 Ford City is the condominium association for the condominium building located at 4280

W. Ford City Drive in Chicago, Illinois. At issue here is unit 207 of that building (“the property”).

On January 4, 2017, the property was sold at a judicial foreclosure sale. Defendant Wilmington

Savings Fund Society FSB DBA Christiana Trust, not in its individual capacity, but solely as

trustee for BCAT 2015-14BTT (“Wilmington”), the mortgagee of the property, was the successful

bidder at the sale. The sale was confirmed on January 26, 2017. On July 26, 2017, Ford City sent

a 30-day demand to Wilmington, demanding payment of $27,379.42 in past due assessments, late

fees, and collection costs. The demand also requested payment of an additional $146.77,

representing $100.00 in attorney’s fees, a $40.00 tract search fee, and $6.77 in certified mailing

costs.

¶5 On August 31, 2017, U.S. Bank, which had been quitclaimed the property by Wilmington

on July 17, 2017, paid Ford City $4,913.19. U.S. Bank claims that this amount represented eight

months of regular assessments of $270.17 from February through September 2017 and eight

-2- 1-19-0112

months of special assessments of $252.00 for the same period. The remainder of the amount was

intended to be a prepayment of the October 2017 assessments. U.S. Bank claims that, pursuant to

section 9(g)(3) of the Condominium Property Act (“Act”) (765 ILCS 605/9(g)(3) (West 2016)),

this payment extinguished any lien Ford City had on the property for unpaid pre-sale common

expenses and collection costs.

¶6 Despite this payment, Ford City denied that U.S. Bank’s payment extinguished the lien on

the property for the unpaid pre-sale assessments. Ford City then instituted this suit, seeking

possession of the property and a judgment against U.S. Bank for the past due assessments, fees,

and costs.

¶7 Following unsuccessful cross-motions for summary judgment, the matter went to trial. The

record does not contain a transcript from the trial. Following the trial, the trial court entered an

order granting possession of the property to Ford City and continuing the matter for ruling on Ford

City’s monetary claim. U.S. Bank filed a motion to reconsider, arguing that its payment of the

post-sale assessments extinguished Ford City’s lien on the property for the unpaid pre-sale

assessments. U.S. Bank also disputed some of the attorney’s fees claimed by Ford City. Ford City

responded by arguing that U.S. Bank’s payment did not extinguish the lien, because the amount

necessary to extinguish the lien was $5,726.13, comprised not only of the assessments, but also

the cost of two sales packets, and attorney’s fees related to the demand notice and correspondence

with U.S. Bank’s counsel. Ford City also argued that U.S. Bank’s payment was not made promptly,

coming seven months after the foreclosure sale.

¶8 Following a hearing on the motion to reconsider and Ford City’s request for attorney’s

fees, the trial court denied U.S. Bank’s motion to reconsider. In doing so, the trial court found that

Ford City’s lien for pre-sale assessments was not extinguished by U.S. Bank’s payment of

-3- 1-19-0112

$4,913.19, because the payment was not prompt under the circumstances of the case and because

U.S. Bank’s payment did not pay any of the post-sale expenses other than the post-sale

assessments. At the same hearing, the trial court heard U.S. Bank’s objections to Ford City’s

requested attorney’s fees, ultimately determining that Ford City was entitled to attorney’s fees of

$8,768 plus costs of $1000.40. The trial court directed Ford City to file an affidavit of common

expenses prior to the entry of a judgment on that issue. Thereafter, Ford City filed an affidavit

stating that the outstanding common expenses due for the property, including pre-sale common

expenses, totaled $32,258.82. On December 28, 2018, the trial court entered judgment against U.S.

Bank in the amount of $32,258.82.

¶9 U.S. Bank then instituted this timely appeal.

¶ 10 ANALYSIS

¶ 11 On appeal, U.S. Bank argues that the trial court erred in concluding that U.S. Bank’s

payment of $4,913.19 did not extinguish Ford City’s lien on the property for unpaid pre-sale

assessments and costs, because the amount of the payment was sufficient to cover all of the post-

sale common expenses, as required by section 9(g)(3) of the Act, and because there is no

requirement that the payment be made promptly. U.S. Bank also argues that the attorney’s fee

award should be reduced, because some of the claimed fees were not sufficiently proven or were

duplicative. We affirm.

¶ 12 Extinguishment of Lien

¶ 13 U.S. Bank’s first contention on appeal is that the trial court erred in holding that Ford City’s

lien on the property for pre-sale assessments, fees, and costs was not extinguished by U.S. Bank’s

payment of $4,913.19. According to U.S. Bank, the Act does not require payment of any expenses

other than common expenses, and the trial court improperly included fees and costs that did not

-4- 1-19-0112

qualify as common expenses under the Act. In addition, U.S. Bank also contends that the Act does

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