Garcia v. Bawcum

2025 IL App (1st) 240802-U
CourtAppellate Court of Illinois
DecidedMarch 14, 2025
Docket1-24-0802
StatusUnpublished

This text of 2025 IL App (1st) 240802-U (Garcia v. Bawcum) 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
Garcia v. Bawcum, 2025 IL App (1st) 240802-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 240802-U

No. 1-24-0802

Order filed March 14, 2025

FIFTH DIVISION

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

MYRIAN GARCIA, ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Cook County. ) v. ) No. 2021L010389 ) DORIS BAWCUM, ROBERT JEWELL, ) Honorable individually and as agent of JEWELL PROP., ) Nichole C. Patton, LLC, an Illinois Limited Liability Company, ) Judge, presiding. d/b/a JEWELL PROP., LLC – 2114 SCOVILLE ) AVENUE, CYNTHIA JEWELL, individually ) and as agent of JEWELL PROP., an Illinois ) Limited Liability Company d/b/a JEWELL ) PROP., LLC -2114 SCOVILLE AVENUE, ) JEWELL PROP., LLC an Illinois Limited ) Liability Company d/b/a JEWELL PROP., LLC - ) 2114 SCOVILLE AVENUE, ) ) Defendants-Appellees. )

JUSTICE MITCHELL delivered the judgment of the court. Presiding Justice Mikva and Justice Oden Johnson concurred in the judgment.

ORDER

¶1 Held: The circuit court did not err in granting summary judgment for the defendant landlords where they did not owe a duty to the plaintiff who was bitten by a tenant’s dog. No. 1-24-0802

¶2 Plaintiff, Myrian Garcia, appeals the circuit court’s order for summary judgment in favor

of defendants Robert Jewell, Cynthia Jewell, and Jewell Prop., LLC. The issue presented is

whether the circuit court erred in granting summary judgment for the defendants because neither

the voluntary undertaking exception nor latent defect exception created a duty to protect the

plaintiff. For the following reasons, we affirm.

¶3 I. BACKGROUND

¶4 The defendants owned property at 2114 Scoville Avenue, Berwyn, Illinois. They leased

the property to defendant Doris Bawcum. The property has a common area in the back which is

bounded by a picket fence on two sides. This fence separates the common area of the property

from the public alley. All parties agree that the fence was “rickety” and had been in a state of

disrepair since Bawcum moved to the property.

¶5 Bawcum’s dog, Titan, escaped her control when she was letting it into the house. The dog

left the defendants’ property by forcing himself through the fence. Once in the alley, Titan bit

plaintiff Myrian Garcia on the leg. Titan had been in two prior reported incidents, neither of which

had been reported to Robert or Cynthia Jewell.

¶6 Garcia filed a complaint against the defendants based on a common law theory of

negligence. She alleged the defendants owed a duty to her on the theory of voluntary undertaking

and a latent defect present on the premises.

¶7 The defendants moved for summary judgment predicated on the supposed absence of a

duty. The circuit court granted the motion, 735 ILCS 5/2-1005 (West 2020), and concluded that

the defendants had no duty because there was no latent defect in the fence, and they had not

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engaged in a voluntary undertaking. This timely appeal followed. Ill. S. Ct. R. 303 (eff. July 1,

2017).

¶8 II. ANALYSIS

¶9 Garcia argues that the circuit court erred in granting summary judgement because there

was evidence of a latent defect in the property and that the defendants engaged in a voluntary

undertaking. These are exceptions to the general rule that “a landlord is not liable for injuries

caused by a dangerous or defective condition on the premises leased to a tenant and under the

tenant’s control.” Klitzka ex rel. Teutonico v. Hellios, 348 Ill. App. 3d 594, 597 (2004) (citing

Vesey v. Chicago Housing Authority, 145 Ill. 2d 404, 413 (1991)). The defendants contend there

was no latent defect and no voluntary undertaking which would create a duty to a third party. We

review the grant or denial of a motion for summary judgment de novo. Cohen v. Chicago Park

District, 2017 IL 121800, ¶ 17. Summary judgment is proper when there is no genuine issue of

material fact and that the moving party is entitled to judgement as a matter of law. Id.

¶ 10 In order to prove a common law negligence claim, a plaintiff must show the existence of

a duty owed by the defendant, a breach of that duty, and an injury proximately resulting from that

breach. Klitzka, 348 Ill. 3d at 596. The existence of a duty is a question of law to be determined

by the court. Id. “Where the plaintiff fails to provide facts ‘from which the court could infer the

existence of a duty,’ summary judgement for the defendant is appropriate.” Id. (quoting Vesey, 145

Ill. 2d 413).

¶ 11 Illinois courts have repeatedly rejected the claim that landlords should be responsible for

dog bites that take place off the leased premises. See Sedlacek v. Belmonte Properties, LLC, 2014

IL App (2d) 130969, ¶ 32 (“Where there was no undertaking of a duty, we will not hold a landlord

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liable for injuries caused to a third person by a tenant’s dog off of the leased property.”); Solorio

v. Rodriguez, 2013 IL App (1st) 121282, ¶ 28 (“[W]e are unwilling to make a landlord an insurer

of the public against injuries caused away from the premises***.”); Klitzka, 348 Ill. 3d at 601

(holding that a landlord owes no duty to a tenant’s invitee to prevent injuries from a tenant’s animal

even on leased premises if the landlord does not control the area where the injury occurred). Here,

the incident took place in a public alley, not on the leased property. Following Illinois’ tradition

of holding the dog’s owner accountable for the dog’s actions, defendants would not normally be

liable for an attack that took place away from the property.

¶ 12 In Illinois, lessors who relinquish control of a property to a lessee owe no duty to third

parties who are injured while on the leased property unless an exception applies. Klitzka, 348 Ill.

3d at 597-98. The court in Klitzka laid out six exceptions, two of which are relevant here: “(1) a

latent defect exists at the time of the leasing that the landlord should know about; *** (6) the

landlord voluntarily undertakes to render a service.” Id. Garcia argues that under these two

exceptions, there was at least a factual question that precludes summary judgement.

¶ 13 “The essential element of the voluntary undertaking doctrine is an undertaking and the duty

of care imposed on a defendant is limited to the extent of his undertaking.” Iseberg v. Gross, 366

Ill. App 3d 857, 865 (2006). The voluntary undertaking exception is narrowly construed. Sedlacek,

2014 IL App (2d), ¶ 30 (citing Bell, 2001 IL 110724, ¶ 12). “[T]he extent of the undertaking is

determined by the reasonable assessment of its underlying purpose.” Sedlacek, 2014 IL App (2d),

¶ 30. In Sedlacek, on nearly identical facts, the appellate court held that only an express promise

to fix the fence so the [rottweiler] would be contained would constitute a voluntary undertaking.

Id. ¶ 31. The Sedlacek court also found the landlord’s original intent to fix the fence to contain

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animals generally had been abandoned through inaction. Id. In this case, there was no promise by

the defendants to fix the fence for any reason, and certainly no promise to make it suitable to

contain a dog. The closest statement in the record is that Robert Jewell said he would maintain the

common area so it would “look nice.” He never promised or attempted to do more than that. With

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Related

Klitzka Ex Rel. Teutonico v. Hellios
810 N.E.2d 252 (Appellate Court of Illinois, 2004)
Vesey v. Chicago Housing Authority
583 N.E.2d 538 (Illinois Supreme Court, 1991)
BOARD OF EDUC. OF MAINE TOWNSHIP HIGH SCHOOL DIST. v. Intern. Ins. Co.
684 N.E.2d 978 (Appellate Court of Illinois, 1997)
Sedlacek v. Belmonte Properties, LLC
2014 IL App (2d) 130969 (Appellate Court of Illinois, 2014)
Solorio v. Rodriguez
2013 IL App (1st) 121282 (Appellate Court of Illinois, 2013)
Cohen v. Chicago Park District
2017 IL 121800 (Illinois Supreme Court, 2017)

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Bluebook (online)
2025 IL App (1st) 240802-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/garcia-v-bawcum-illappct-2025.