Forest Preserve District of Cook County v. Chicago Title & Trust Co.

2020 IL App (1st) 191527-U
CourtAppellate Court of Illinois
DecidedNovember 20, 2020
Docket1-19-1527
StatusUnpublished

This text of 2020 IL App (1st) 191527-U (Forest Preserve District of Cook County v. Chicago Title & Trust Co.) 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
Forest Preserve District of Cook County v. Chicago Title & Trust Co., 2020 IL App (1st) 191527-U (Ill. Ct. App. 2020).

Opinion

2020 IL App (1st) 191527-U November 20, 2020

SIXTH DIVISION

No. 1-19-1527

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

THE FOREST PRESERVE DISTRICT OF ) Appeal from the Circuit Court of COOK COUNTY, ILLINOIS, a body corporate ) Cook County, Law Division. and politic of the State of Illinois, ) ) Plaintiff-Appellant, ) ) v. ) No. 16 L 50357 ) CHICAGO TITLE AND TRUST COMPANY, ) an Illinois Corporation, AS SUCCESSOR ) TRUSTEE OF AMERICA TRUST COMPANY, ) AS TRUSTEE UNDER TRUST AGREEMENT ) DATED DECEMBER 18, 1992, AND KNOWN ) AS TRUST NUMBER 36-4033; and ) ALLEN HOGER, ) ) Defendants-Appellees ) ) (Manufacturers Bank, an Illinois Banking ) Corporation; Illinois Bell Telephone, an Illinois ) Corporation; and Unknown Owners, ) ) Honorable Defendants). ) Michael F. Otto, ) Judge Presiding.

JUSTICE GRIFFIN delivered the judgment of the court. Presiding Justice Mikva and Justice Connors concurred in the judgment.

ORDER No. 19-1527

¶1 Held: The judgment of the Circuit Court of Cook County is affirmed. Fundamental unfairness would not result from the application of res judicata to this case.

¶2 Plaintiff Forest Preserve District of Cook County, Illinois (District), attempted to pass an

ordinance in 1991, that would give it authority to negotiate and take by eminent domain private

property situated between two forest preserves in unincorporated Cook County. For years the

District used the ordinance to take private property until a landowner moved to dismiss

condemnation proceedings brought by the District on the basis that the ordinance was never passed

in 1991, and the District was therefore acting without enabling authority. Two trial courts agreed

that the ordinance was invalid and dismissed the condemnation proceedings.

¶3 By that time, defendant Allen Hoger and his wife (Hoger) had already settled with the

District and sold their land. Hoger was the beneficiary of a land trust, which held title to his

property. The successor trustee was Chicago Title and Trust Company. After the trial court

invalidated the ordinance, Hoger returned to court to undo the settlement, arguing that the trial

court never would have entered judgment had it known the ordinance was invalid. The District

relentlessly opposed Hoger’s claim for relief, as it did in each proceeding where a private

landowner raised the defense of an invalid enabling ordinance.

¶4 Litigation ensued and continued for several years until the parties had briefed the same

issue so many times that the trial court—citing this Court’s decision to affirm the judgments which

invalidated the ordinance—allowed Hoger to file a second amended petition pursuant to section

2-1401 of the Code of Procedure (735 ILCS 5/2-1401 (West 2008)). In addition to granting leave

to file, the trial court in a written order addressed the merits of the petition and found that, even

though an evidentiary hearing on due diligence was not held, Hoger had satisfied the requirements

of section 2-1401. Hoger’s petition was later granted and the District appealed.

¶5 We affirmed the judgment of the trial court on appeal, finding in part that the equities

2 No. 19-1527

favored relaxing the requirement of an evidentiary hearing on the issue of Hoger’s due diligence.

We concluded that, even if Hoger had knowledge of the potential invalidity of the ordinance, he

nevertheless was entitled to rely on the myriad misrepresentations made by the District that it in

fact had enabling authority when it in fact did not. We also found support in the record for trial

court’s finding that the District actively concealed the invalidity of the ordinance such that the

vacation of the judgment approving the settlement agreement was warranted.

¶6 After the case returned to the trial court, the District filed its own section 2-1401 petition,

claiming that newly discovered evidence showed that Hoger had actual knowledge of the

ordinance’s invalidity before he settled. The District maintained that, had the trial court known of

this fact, it would not have entered judgment vacating its approval of the settlement agreement.

¶7 On a motion for summary judgment, the trial court found that the District was attempting

to relitigate the issue of Hoger’s due diligence, which had been resolved on appeal, and determined

that Hoger’s potential knowledge of potential defense to the invalidity of the ordinance was either

considered irrelevant based on the finding that he was entitled to rely on the District’s

misrepresentations that it possessed the authority to condemn. The trial court granted summary

judgment in favor of Hoger and against the District. The District timely appealed. For the following

reasons, we affirm.

¶8 BACKGROUND

¶9 In the early 1990’s, the District implemented a plan to acquire 285 acres of private land

situated between the Tampier Lake and McGinnis Slough Forest Preserves in unincorporated Cook

County. The land would serve to connect the two forest preserves and create a “greenway” between

them. On March 20, 1991, to facilitate its acquisition of the land, the District attempted to adopt

an ordinance authorizing it to take the privately-owned parcels by eminent domain (Ordinance).

3 No. 19-1527

The District divided the parcels, assigned them numbers between 1 and 23, and moved forward to

complete the “Tampier Lake Greenway Project” (Project) through negotiation or condemnation.

¶ 10 For more than a decade the District used the Ordinance to complete the Project. In the early

2000’s, however, the Project faced a setback. Courts invalidated the procedure by which the

Ordinance was passed, describing it as so fatally flawed that Ordinance never came into existence.

Along with the validity of the Ordinance went the legal authority it provided the District to

negotiate and take private property for the Project. A rush to court ensued and the private

landowners who had settled with the District took action to undo their settlement agreements.

¶ 11 One such landowner was Hoger, who settled with the District in May 2003, and sold his

14.6-acre property located at 11441 West 135th Street in unincorporated Orland Township

(Property) for a total of 1.7 million. In 2004, Hoger petitioned the trial court to vacate its judgment

on the basis that it never would have approved the settlement had it known the Ordinance was

invalid. After we affirmed the invalidity of the Ordinance in a consolidated appeal, the trial court

granted the requested relief and vacated its judgment. The District appealed, and we affirmed. Our

Supreme Court denied leave to appeal and a mandate issued.

¶ 12 The proceedings resumed in the trial court and the District claimed to have unearthed new

evidence that would warrant the reinstatement of the settlement agreement. According to the

District, newly discovered evidence showed that Hoger had “actual knowledge” of the Ordinance’s

invalidity when he settled and had the trial court been aware of this “fact,” it never would have

entered judgment to vacate its prior approval of the settlement.

¶ 13 The trial court rejected the District’s request for relief, finding that it was attempting to

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Cite This Page — Counsel Stack

Bluebook (online)
2020 IL App (1st) 191527-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/forest-preserve-district-of-cook-county-v-chicago-title-trust-co-illappct-2020.