In re Estate of Richardson

2025 IL App (1st) 242200-U
CourtAppellate Court of Illinois
DecidedAugust 15, 2025
Docket1-24-2200
StatusUnpublished

This text of 2025 IL App (1st) 242200-U (In re Estate of Richardson) 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 Estate of Richardson, 2025 IL App (1st) 242200-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 242200-U

SIXTH DIVISION August 15, 2025

No. 1-24-2200

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 ESTATE OF MARY L. RICHARDSON, ) Deceased, ) ) Appeal from the (SHAMEKA V. RICHARDSON, Independent ) Circuit Court of Administrator, ) Cook County ) Petitioner-Appellant, ) No. 2023 P 005681 ) v. ) The Honorable ) Kent A. Delgado, VAQUITA DAVIS and TARONNA DAVIS, ) Judge presiding. ) Respondents-Appellees.) )

PRESIDING JUSTICE TAILOR delivered the judgment of the court. Justices Hyman and Gamrath concurred in the judgment.

ORDER

¶1 Held: The judgment of the circuit court is affirmed. The trial court properly granted respondents’ motion to dismiss based on the doctrine of laches.

¶2 I. BACKGROUND

¶3 Mary Richardson and her husband, Perry Richardson Sr., had 10 children together: Linda,

Larry, Denise, Donald, Michael, Perry Jr., Kenneth, Willard, Norman, and Jerrod. Perry Sr. passed

away, and Mary subsequently died intestate on March 23, 1996. Her son, Michael, passed away No. 1-24-2200

on February 21, 2023, and was survived by his daughters/respondents, Vaquita Davis and Taronna

Davis (Respondents).

¶4 On August 16, 2023, Linda filed a Petition for Letters of Administration, nominating her

daughter, Shameka Richardson, as the proposed independent administrator for Mary’s estate. On

September 18, 2023, the court appointed Shameka as independent administrator, and the Letters

of Office authorized her to take possession of Mary’s estate.

¶5 On October 11, 2023, Shameka filed a Petition for Issuance of Citation in Recovery and

for Other Relief, alleging that at the time of Mary’s death, Mary held an interest in the real property

located at 1956 S. Springfield Avenue in Chicago, and that “no deed or other transfer document

had been recorded transferring title to any other person, so at the time of her death the Real Estate

was in her name alone.” The Springfield Avenue property was Mary’s only purported probate

asset. When Linda “began to look into administering the [Springfield Avenue Property] on behalf

of [Mary’s] estate,” she “discovered that *** a Quit Claim Deed was recorded which purportedly

quit claimed [Mary’s] interest [in the Springfield Avenue Property] from herself to Michael.” The

deed, which was attached to the petition, shows that it was signed by Mary on June 1, 1995, and

recorded with the Cook County Clerk’s Office two years later on July 3, 1997, after Mary had

died.

¶6 The petition alleged a single count – lack of delivery – and claimed that because the quit

claim deed was not recorded during Mary’s lifetime, there was no presumption of valid delivery.

It also claimed that “[u]pon information and belief, during her lifetime, [Mary] made

representations to her friends and family that she was the sole owner of the Real Estate and she

never made any representations that she transferred her interest in the [Springfield Avenue

Property] to Michael.” It also alleged that Respondents had been “collecting rent at the [Springfield

2 No. 1-24-2200

Avenue Property] which belongs to [Mary’s] estate.” Shameka asked the court to declare the quit

claim deed void and invalid due to inadequate delivery, to compel Respondents to sign documents

transferring their interest in the Springfield Avenue Property to Mary’s estate, and to prepare an

accounting of all rents received since Michael’s death.

¶7 On March 7, 2024, Respondents filed a motion to dismiss Shameka’s petition. They

asserted that prior to Mary’s death, she executed a quit claim deed conveying her interest in the

Springfield Avenue Property to her son, Michael, and that Michael recorded this deed on July 3,

1997. Therefore, they argued that the property did not belong to Mary’s estate. Respondents

alternatively argued that Shameka’s petition should be dismissed under the doctrine of laches,

because she waited more than 27 years to probate Mary’s estate and to assert a claim for title to

the Springfield Avenue Property, at which point “the principal witness [Michael] who could testify

*** was no longer available to contradict [her].” Respondents argued that the recording of the deed

in 1997 provided constructive notice to Shameka that Mary’s estate no longer possessed the

property, and therefore she failed to act with due diligence by failing to bring suit until 27 years

after Mary’s death. Respondents also argued that they would suffer prejudice if Shameka was

allowed to proceed with her claim, because “the monetary investments and efforts made by

Michael and his heirs would unjustly enrich the other heirs of [Mary] to the detriment of the

rightful owner.” In their reply to Shameka’s response, Respondents attached their own affidavits,

in which they asserted that their father Michael “made numerous public declarations to various

family members that the Springfield Avenue Property was his own property,” that he “put in [a]

tremendous amount of work and expended significant funds in maintaining the Springfield

[Avenue] Property *** because it was his responsibility as the owner” and that he “paid the

property taxes, mortgage payments, [and] utility bills for the property.” They also attached an

3 No. 1-24-2200

affidavit from Roseland Watt, who averred that she lived at the Springfield Avenue Property and

that Michael was the owner and her only landlord until he passed away.

¶8 Following a hearing on June 18, 2024, the court found that “the recording of the Quit Claim

Deed provided notice to the world that Michael Richardson had record title to the property” and

granted Respondents’ motion to dismiss based on the affirmative defense of laches. It stated that

Shameka had an opportunity to assert a claim against the Springfield Avenue Property between

July 3, 1997, and February 21, 2023, yet failed to do so. The court also found that it would

prejudice Respondents to allow the case to move forward more than 27 years after Mary’s death

since “6 of 10 of [Mary’s] heirs have died since 1997 and are unavailable to testify.” It also found

that “if the Citation to Recover were to be granted Citation Respondents would suffer harm in that

they would lose income and equity in the property and suffer other damages and would be

prejudiced by the death of the potential witnesses in the time since the recording of the Quitclaim

Deed.” In its order, the court expressly noted that the affidavits attached to Respondents’ reply

were “not - - being considered by the court because they were not filed with the Motion to Dismiss.”

¶9 Shameka filed a motion to reconsider, with attached affidavits from her mother Linda and

Linda’s sister Denise. In these affidavits, Linda and Denise claimed they had a witness, Ricky

Richardson, who could testify regarding the “forgery of the Quit Claim Deed.” Shameka argued

that the trial court erred when it granted Respondents’ motion to dismiss based on the doctrine of

laches because it “did not swear in or examine the petitioner [Shameka] or Respondent Davis

before making its findings.” Shameka also argued that “[a]lthough the period of time on which

laches is predicated normally begins to run either when the plaintiff learns of the facts on which

his rights are based or when a reasonable person would acquire such knowledge,” Michael owed

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Bluebook (online)
2025 IL App (1st) 242200-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-richardson-illappct-2025.