In re Application of the County Treasurer

2025 IL App (1st) 232444-U
CourtAppellate Court of Illinois
DecidedAugust 7, 2025
Docket1-23-2444
StatusUnpublished

This text of 2025 IL App (1st) 232444-U (In re Application of the County Treasurer) 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
In re Application of the County Treasurer, 2025 IL App (1st) 232444-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 232444-U Fourth Division Filed August 7, 2025 No. 1-23-2444

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

In re APPLICATION OF THE COUNTY TREASURER ) AND EX OFFICIO COUNTY COLLECTOR OF ) COOK COUNTY, ILLINOIS, for Order of Sale Against ) Appeal from the Real Estate Rendered Delinquent for the Non-Payment ) Circuit Court of Cook County of General Taxes for the Year 2017 and Prior Years ) No. 2021 COTD 001467 ) (Newline Holdings, LLC, Petitioner-Appellant, ) The Honorable Kathleen Burke, v. ) Judge, presiding. Maria Pappas, as Cook County Treasurer and ex officio ) Cook County Collector, Appellee). )

JUSTICE OCASIO delivered the judgment of the court. Presiding Justice Rochford and Justice Lyle concurred in the judgment.

ORDER

¶1 Held: The appeal was dismissed as moot where, by operation of law, the tax purchaser relinquished its rights under the certificate of payment by returning the certificate to the county clerk and accepting the clerk’s tender of the redemption payment and a refund of an unposted tax payment.

¶2 Newline Holdings, LLC (Newline), was the assignee of a tax certificate for the 2017

delinquent taxes on a parcel of real property located at the corner of 71st Street and Jeffrey Avenue

in Chicago. Newline filed a petition for a tax deed and, in furtherance of the petition, paid the

delinquent 2019 second installment taxes on the property. Although Newline submitted

documentation of the payment to be posted on the official record maintained by the county clerk No. 1-23-2444

(the judgement book), notice of that payment was not actually posted. So, when an agent of the

property owner exercised the right of redemption, the second 2019 tax payment was not included

in the redemption amount. After the circuit court denied Newline’s bid to set aside the redemption,

Newline relinquished its certificate and accepted the clerk’s tender of the redemption money

(which included interest) and the refund of the unposted payment (which did not). The court

subsequently declined Newline’s request that it order the county to compensate it for the statutory

interest Newline would have received had the payment been properly posted.

¶3 On appeal, Newline renews its argument that the county should be required to pay statutory

interest on the unposted payment. We find, however, that Newline’s return of the certificate and

acceptance of the money tendered by the clerk renders its claimed entitlement to interest moot.

Accordingly, we dismiss the appeal.

¶4 I. BACKGROUND

¶5 On May 6, 2019, Newline’s predecessor-in-interest purchased the 2017 delinquent taxes of

the subject property and was issued a certificate of purchase. After being assigned the certificate

of purchase, Newline petitioned for a tax deed to the property. The redemption date was set as

January 10, 2022.

¶6 Newline paid numerous additional tax bills on the property after they became delinquent

while the petition was pending. It paid both the first and second tax installments for 2018, as well

as the first installment for 2019. Newline posted a payment notice with the county clerk for each

of the three payments, and the clerk stamped each notice with the date of receipt. The first and

second installments of 2018 and the first installment of 2019 were thus posted to the 2017 Tax

Judgment, Sale, Redemption, and Forfeiture Record (judgment book) and added to the redemption

amount that the property owner was required to pay, which came to $154,105.81.

¶7 On March 12, 2021, Newline paid the second installment of the 2019 taxes in the amount of

$135,863.28. The record does not include a posting notice of the 2019 second installment that was

-2- No. 1-23-2444

file stamped as received by the county clerk, and the payment was not recorded in the clerk’s

judgment book.

¶8 On January 7, 2022, Alisa Starks, an agent for the property owner, made a timely redemption

payment to the Cook County Clerk. The payment was based on the amount listed in the judgment

book, so it did not include Newline’s second installment payment of $135,863.28 posting or

interest accrued thereon.

¶9 On August 4, 2022, Newline filed a motion to set aside the January 7 redemption, noting that

Starks’s redemption payment had not included the $135,863.28 plus interest from the second 2019

installment payment. The motion asserted that, when Newline made that payment, it followed the

procedures adopted by the clerk in 2020 to facilitate the posting of tax payments on the clerk’s

judgment book and that the clerk did not reject the posting. It asked the court to set aside the

redemption and direct the clerk to issue a shortage letter to Starks.

¶ 10 On March 15, 2023, the circuit court denied Newline’s motion after a hearing. The court’s

written order indicates that the motion was “denied for the reasons stated in open court.” The

record does not contain a transcript of the hearing.

¶ 11 On April 11, 2023, the circuit court ordered the county clerk’s office to issue a “deletion letter”

to the county treasurer in the amount of Newline’s $135,863.28 second 2019 installment payment.

It further ordered the treasurer to “refund” Newline that same amount. The record indicates that,

at some point before September 2023, Newline received that refund from the county.

¶ 12 On May 2, 2023, the circuit court ordered the county clerk’s office to refund Newline the

remaining $154.092.81 upon turnover of the certificate of purchase. It appears that, at some point

before taking this appeal, Newline turned over the certificate of purchase and received the

$154,092.81 refund.

¶ 13 On June 29, 2023, Newline filed a “Motion to Determine Reimbursement.” The motion

argued that Newline was entitled to interest on the unposted second 2019 installment payment

from the date of the payment through the date of redemption, which it calculated as an additional

$16,303.59.

-3- No. 1-23-2444

¶ 14 At a hearing on the motion to determine reimbursement, Newline conceded that Starks had

properly redeemed the property and was not obligated to pay the interest it was seeking. Instead,

Newline proposed that the county should be responsible for paying interest on the unposted

amount, suggesting that the county could draw on either its “general fund” or its “sale in error

fund” to do so.

¶ 15 On November 22, 2023, the circuit court denied Newline’s motion. This appeal follows.

¶ 16 II. ANALYSIS

¶ 17 Newline argues that it was entitled to interest on the refund of the unposted second 2019

installment payment. It contends, in essence, that it followed the clerk’s rules when it submitted

the posting for that payment, that the failure to actually make the posting was the fault of the clerk,

and that it was entitled to be made whole by being paid the interest it would have received at

redemption but for the clerk’s mistake. The only authority Newline cites for its entitlement to

interest are the provisions of the Property Tax Code (35 ILCS 200/1-1 to 32-20 (West 2022)).

¶ 18 We agree with the county that Newline’s acceptance of the redemption payment and surrender

of the certificate of purchase makes this appeal moot. “An issue is moot where an actual

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Bluebook (online)
2025 IL App (1st) 232444-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-application-of-the-county-treasurer-illappct-2025.