Goudanis v. Village of Hillside

2025 IL App (1st) 242300-U
CourtAppellate Court of Illinois
DecidedSeptember 26, 2025
Docket1-24-2300
StatusUnpublished

This text of 2025 IL App (1st) 242300-U (Goudanis v. Village of Hillside) 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
Goudanis v. Village of Hillside, 2025 IL App (1st) 242300-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 242300-U

FIFTH DIVISION September 26, 2025

No. 1-24-2300

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 DISTRICT

LOUIS GOUDANIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Cook County ) v. ) No. 2023 L 3013 ) VILLAGE OF HILLSIDE, ) The Honorable ) Stephanie D. Saltouros, Defendant-Appellee. ) Judge Presiding.

JUSTICE TAILOR delivered the judgment of the court. Presiding Justice Mitchell and Justice Mikva concurred in the judgment.

ORDER

¶1 Held: The trial court properly granted summary judgment to defendant based on the Local Governmental and Governmental Employees Tort Immunity Act.

¶2 I. BACKGROUND

¶3 On August 16, 2022, Louis Goudanis was walking home from a concert when he tripped

and fell on an uneven sidewalk near the intersection of East End Avenue and Washington Street

in Hillside, Illinois. He sustained injuries as a result. No. 1-24-2300

¶4 On March 28, 2023, Goudanis filed a complaint against the Village of Hillside (Village),

alleging that the Village had actual or constructive notice of the uneven sidewalk upon which he

fell “a long time prior” to August 16, 2022, and yet permitted the dangerous condition to remain.

¶5 In its response, the Village admitted it was aware that the sidewalk at issue was raised or

uneven, but denied that the condition of the sidewalk was unreasonably dangerous. It said that

while temporary remedial measures could have been taken, “a conscious decision was made to

take no action.” It asserted three affirmative defenses, arguing (1) any sidewalk issue was de

minimis and not actionable; (2) Goudanis was contributorily negligent; and (3) “[a]s a local public

entity, [the Village] is entitled to avail itself of immunities afforded to it pursuant to the Local

Governmental and Governmental Employees Tort Immunity Act.” (Tort Immunity Act).

¶6 In his deposition, Goudanis testified that on August 16, 2022, he went to Hillside to see a

band, and parked on East End Avenue, near the intersection of Washington Street. Around 9 pm,

after the concert finished, he walked back to his car. He said he was “just looking straight ahead”

and “wasn’t really looking straight down at the sidewalk” as he walked. One of his toes got caught

on uneven pavement and that caused him to fall. His head hit the concrete, and he ended up in the

grass. Paramedics arrived 5-10 minutes later and took him to the hospital. His sister returned to

the accident site a few days later and took photos of the raised/uneven sidewalk square. Goudanis

said the sidewalk square was displaced “approximately two inches.” Goudanis said he did not

know how long the sidewalk had been in that condition, because he had never been to that area of

Hillside before.

¶7 A Hillside police department incident report states that on August 16, 2022, around 9:18

pm, Officer Yohanne Nelson was dispatched to the intersection of East End Avenue and

Washington Street to assist the fire department with a man who fell. Paramedics were assisting

2 No. 1-24-2300

Goudanis, who fell and was bleeding from the head. Goudanis was transported to Elmhurst

Hospital by ambulance. When Officer Nelson spoke to Goudanis at the hospital, he said he tripped

on the uneven pavement on the sidewalk and struck his head, causing a laceration over his right

eye. Officer Nelson took photos of the sidewalk where Goudanis had fallen.

¶8 A verified statement by Robert McDonald was submitted by Goudanis. McDonald stated

that he resided at 525 East End Avenue, which is located at the corner of East End Avenue and

Washington Street. On September 28, 2021, he contacted the Village to inquire about its 50/50

sidewalk program and the possible replacement of the sidewalk squares on Washington Street at

issue here. On or about September 30, 2021, he received the “sidewalk renewal – village of

Hillside” form, which quoted $7350 for the replacement of 21 sidewalk squares on the sidewalks

near his home with his share being $3675. McDonald did not sign or authorize the sidewalk

replacement because the cost was too high. After he received the quote, he did not follow up with

the Village. He did not witness Goudanis’ accident and had no information about it.

¶9 During his deposition, McDonald testified that he contacted the Village in September 2021

“[b]ecause [he] didn’t like how [the sidewalk in front of his house] looked and it wasn’t really kind

of, like, level. There was a lot of cracked concrete.” He was unaware of anyone ever tripping or

falling on the sidewalk near his home, however, and he had never had any issues walking there.

Ultimately, he did not agree to participate in the Village’s 50/50 program to replace the concrete

sidewalk squares near his home because the cost the Village quoted him was too high. He did not

have any further discussions with the Village about fixing the sidewalk, but eventually the Village

replaced the sidewalk on its own at no cost to him.

¶ 10 In his deposition, Paul Smith testified that he was the director of public works for the

Village and that he had held that position since May 2023. He had previously served as the assistant

3 No. 1-24-2300

director from 2003 until May of 2023. He explained that the Village does not have a formal

inspection program to monitor the condition of the Village’s sidewalks, and instead, relies on

“observation or residential inquiry.” He said the 50/50 Program is a residential participation

program with the Village for sidewalk replacement. If a resident comes to the Village and wants

his sidewalk replaced, Smith goes to “do an onsite assessment of what the current conditions are”

and “make[s] a determination on what sidewalk squares potentially would be replaced.” When

Smith does these inspections, he is “looking for obvious conditions that would really warrant

replacement, whether that is a crack or a depression.” There is no document that the Village uses

to determine whether a sidewalk needs replacing,” and it is entirely up to Smith. He is the only

one from the Village who conducts these inspections. The Village will then quote the resident a

price for the repair. The Village will pay half the cost and the resident is expected to pay the other

half. The Village gets about two dozen 50/50 requests a year, but only 25-30% of the homeowners

choose to participate in the program. Smith testified that if he sees a condition on the sidewalk

during one of these 50/50 inspections that is “obviously dangerous” and the resident declines to

pay for their half, the Village still occasionally decides to do repairs on its own. He testified that

he remembered the Village doing so maybe “four or five times.”

¶ 11 After the Village got a service request from McDonald on September 28, 2021, to replace

the sidewalk near his home, Smith went to inspect it. On September 30, 2021, Smith documented

the 21 sidewalk squares he believed he needed replacement. The Village did not replace with

sidewalk squares, however, because the homeowner elected not to participate in the 50/50

program. When Smith was asked if there were other reasons the Village chose not to replace the

sidewalk squares near McDonald’s home, he said, “I guess I also didn’t necessarily feel that any

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Bluebook (online)
2025 IL App (1st) 242300-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/goudanis-v-village-of-hillside-illappct-2025.