Housing Authority of the County of Cass v. Assisted Housing Risk Management Ass'n

2020 IL App (4th) 180737-U
CourtAppellate Court of Illinois
DecidedApril 13, 2020
Docket4-18-0737
StatusUnpublished

This text of 2020 IL App (4th) 180737-U (Housing Authority of the County of Cass v. Assisted Housing Risk Management Ass'n) 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
Housing Authority of the County of Cass v. Assisted Housing Risk Management Ass'n, 2020 IL App (4th) 180737-U (Ill. Ct. App. 2020).

Opinion

NOTICE 2020 IL App (4th) 180737-U This order was filed under Supreme FILED Court Rule 23 and may not be cited NO. 4-18-0737 April 13, 2020 as precedent by any party except in Carla Bender the limited circumstances allowed IN THE APPELLATE COURT 4th District Appellate under Rule 23(e)(1). Court, IL OF ILLINOIS

FOURTH DISTRICT

HOUSING AUTHORITY OF THE COUNTY OF CASS, ) Appeal from the ILLINOIS, ) Circuit Court of Plaintiff-Appellant, ) Cass County v. ) No. 11L8 ASSISTED HOUSING RISK MANAGEMENT ) ASSOCIATION (AHRMA), ) Honorable Defendant-Appellee. ) Bob Hardwick Jr., ) Judge Presiding.

JUSTICE DeARMOND delivered the judgment of the court. Presiding Justice Steigmann and Justice Holder White concurred in the judgment.

ORDER ¶1 Held: The appellate court affirmed, finding the trial court did not abuse its discretion in denying plaintiff’s motion to deem facts admitted, denying its motion to strike defendant’s affirmative defenses, denying its motion to bar an adverse witness, or denying its motion barring defendant from referencing the Federal Emergency Management Association (FEMA). Additionally, the trial court did not err in granting defendant’s motion for partial summary judgment on lost rental income.

¶2 After a windstorm in June 2010, plaintiff, Housing Authority of the County of

Cass, Illinois, the owner of an apartment building, filed insurance claims with defendant,

Assisted Housing Risk Management Association (AHRMA), its insurance provider. Plaintiff

claimed the windstorm caused structural damage to the apartment building covered under the

insurance contract. Plaintiff filed its complaint in December 2011, alleging it had suffered lost

rental income and other losses associated with either demolishing or rehabilitating the inhabitable structure. Plaintiff alleged the relevant insurance contract with defendant (spanning

January 1, 2010, to January 1, 2011) covered both claims.

¶3 In June 2018, after approximately seven years of litigation, a jury found in favor

of defendant. The jury’s verdict found coverage for structural damage caused by the windstorm

was provided by the insurance contract; however, defendant proved at least one affirmative

defense defeating coverage.

¶4 Plaintiff appeals, arguing the trial court erred in (1) denying its motion to deem

facts admitted, (2) incorrectly concluding defendant’s affirmative defenses were jury questions

(3) denying its motion to strike defendant’s third amended affirmative defenses, (4) denying

plaintiff’s motion to bar adverse witness Steve Horton from testifying, (5) denying plaintiff’s

motion to bar any mention of involvement of the Federal Emergency Management Association

(FEMA), and (6) granting defendant’s partial motion for summary judgment on the issue of loss

of rental income.

¶5 We affirm.

¶6 I. BACKGROUND

¶7 In June 2010, plaintiff owned an apartment complex with approximately 16 rental

units in Beardstown, Illinois. That month, a storm with high winds blew through the town,

causing structural damage to the apartment complex. After the storm, the building’s foundation

shifted, and the building eventually became uninhabitable. Plaintiff alleged the windstorm

caused or significantly contributed to the building’s damaged foundation and such damage was

covered under the insurance contract between plaintiff and defendant. Plaintiff further alleged

the foundation damage required the property to be vacated. Plaintiff filed a property claim with

defendant in June 2011. Following inspections by an architect and a structural engineer,

-2- defendant denied plaintiff’s insurance claim. Plaintiff filed its complaint in December 2011,

claiming it suffered lost rental income and other losses associated with either demolishing or

rehabilitating the structure. Plaintiff alleged the relevant insurance contract with defendant

(applicable from January 1, 2010, to January 1, 2011) covered both claims.

¶8 Defendant argued that under the applicable contract between the parties, there was

no coverage for these claims. Defendant asserted as affirmative defenses five specific exclusions

within the insurance contract exempting coverage.

¶9 This case plodded through approximately seven years of litigation before

culminating in a weeklong jury trial in June 2018. On appeal, plaintiff argues the trial court erred

in deciding numerous pretrial discovery issues as well as motions raised during both the pretrial

and trial phases of litigation. In addressing those issues raised by plaintiff’s brief and argument,

we provide only relevant background information as it relates to those particular claims.

¶ 10 In June 2018, the jury returned a verdict for defendant, finding coverage for

structural damage caused by the windstorm was provided by the insurance contract; however,

defendant proved at least one affirmative defense defeating coverage.

¶ 11 This appeal followed.

¶ 12 II. ANALYSIS

¶ 13 A. Plaintiff’s Motion to Deem Certain Facts Admitted

¶ 14 Under Illinois Supreme Court Rule 216(a) (eff. May 30, 2008), “[a] party may

serve on any other party a written request for the admission by the latter of the truth of any

specified relevant fact set forth in the request.” The facts contained in the request are admitted

within 28 days, unless the responding party denies the admissions, providing reasons why the

party cannot either admit or deny the request, or raises a written objection to the request. Ill. S.

-3- Ct. R. 216(c) (eff. May 30, 2008). A responding party must make a reasonable effort to respond

to an opposing party’s request to admit within the responding party’s reasonable control.

Szczeblewski v. Gossett, 342 Ill. App. 3d 344, 349, 795 N.E.2d 368, 372 (2003). “A request to

admit is proper if it relates to statements or opinions of fact or the application of law to fact.”

Troyan v. Reyes, 367 Ill. App. 3d 729, 739, 855 N.E.2d 967, 976 (2006) (citing P.R.S.

International, Inc. v. Shred Pax Corp., 184 Ill. 2d 224, 236, 703 N.E.2d 71, 77 (1998)).

However, a reviewing court will not disturb a trial court’s ruling on discovery matters unless the

trial court abused its discretion. Reda v. Advocate Health Care, 199 Ill. 2d 47, 54, 765 N.E.2d

1002, 1007 (2002). An abuse of discretion occurs when no reasonable person would take the

view adopted by the trial court. Kim v. Mercedes-Benz, U.S.A., Inc., 353 Ill. App. 3d 444, 452,

818 N.E.2d 713, 720 (2004). As noted by defendant, requests to admit may be contained within

the pretrial discovery section of the Illinois Supreme Court Rules (Part E.) and are considered a

part of the discovery process. However, their true purpose is not the discovery of facts but to

establish as fact certain material facts in a cause of action without the necessity of formal proof

at trial. Vision Point of Sale, Inc. v. Haas, 226 Ill. 2d 334, 346, 875 N.E.2d 1065, 1074 (2007)

(quoting P.R.S. International, 184 Ill. 2d at 237).

¶ 15 In January 2013, plaintiff served on defendant 24 requests to admit certain facts.

In February 2013, defendant responded to plaintiff’s requests. For each response, defendant

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