In re Richey

104 B.R. 5, 1989 Bankr. LEXIS 1419, 1989 WL 99740
CourtUnited States Bankruptcy Court, S.D. Illinois
DecidedAugust 28, 1989
DocketBankruptcy No. BK 88-41047
StatusPublished

This text of 104 B.R. 5 (In re Richey) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Richey, 104 B.R. 5, 1989 Bankr. LEXIS 1419, 1989 WL 99740 (Ill. 1989).

Opinion

MEMORANDUM AND ORDER

KENNETH J. MEYERS, Bankruptcy Judge.

The parties to this proceeding are not strangers. In fact, they have quite a history of litigation with one another. The issue this Court must decide involves litigation which began in 1975 when John R. Hieber, Frank Hieber and Leo Culligan (plaintiffs) brought suit in Cook County Circuit Court against A.A. Richey and Gladys Richey (defendants). The suit was brought against defendants both individually and doing business as Double A Oil Producers, Inc. (Double A) for allegedly inducing plaintiffs to invest money in Double A based on false representations.

The defendants were personally served and filed a special appearance, which later became a general appearance. The defendants filed an answer and participated in the pretrial proceedings. However, the defendants did not appear for trial and a [6]*6default judgment was entered against them on July 27, 1977. The judgment order was signed May 9, 1978.

On November 27, 1979, two and one-half years from entry of the default, and one and one-half years from when the judgment order was signed, the defendants filed a pro se petition to vacate the default judgment and subsequently retained counsel. Defendants’ petition to vacate alleged that the default judgment was improperly and erroneously entered, and was void because no notice of the trial was given to defendants. The trial court denied defendants’ petition.

The defendants then appealed to the First District Appellate Court. On appeal, defendants contended that they had no notice of the July 27, 1977 trial date and that the trial court erred in denying their petition to vacate the default judgment. The Appellate Court affirmed the trial court and further denied a petition for rehearing. Review by the Illinois Supreme Court was also sought and denied.1

On January 14, 1982, defendants filed a quiet title action in Richland County, Illinois. Defendants alleged that a memorandum of the Cook County judgment had been recorded in the Office of the Recorder of Deeds in Richland County, Illinois, and that the judgment was a cloud on the real estate. Defendants further alleged that the default judgment was void because defendants were not given notice of the trial date. The plaintiffs did not answer the Richland County complaint and on May 28, 1982, a default judgment was entered in favor of defendants.

Upon entry of the Richland County judgment the plaintiffs filed a motion to vacate the default judgment. On January 4, 1983, the Richland County Circuit Court denied the motion to vacate as to John R. Hieber, but granted the motion as to Frank Hieber and Leo Culligan. John Hieber appealed the denial of the motion to vacate, but the appeal was dismissed for lack of jurisdiction. No further action has been taken in the Richland County proceedings.2

On May 28, 1987, the Cook County Circuit Court entered a judgment reviving the May 9, 1978 default judgment. The judgment of revival was entered for $101,000.00 plus 8% interest from May 9, 1978, or roughly $181,800.00.

In what seems to be a final attempt to collaterally attack the Cook County judgment, Gladys Richey filed a petition under chapter 11 of the Bankruptcy Code on November 8,1988.3 The plaintiffs filed claims based on the Cook County judgment, and debtor objected to the claims alleging once again that the default judgment was invalid because debtor did not receive notice of the trial. This cause is before the Court on debtor’s objection to claims.

The issue before the Court is what pre-clusive effect must be given to the Cook County Circuit Court order denying defendants’ petition to vacate. Determination of [7]*7this issue requires an examination of the principle of collateral estoppel. Collateral estoppel or issue preclusion typically involves a finding of fact by a trial court which binds all subsequent proceedings as to that factual finding. Paine Webber, Inc. v. Farnam, 870 F.2d 1286 (7th Cir.1989); Telegraph Savings and Loan Association v. Schilling, 105 Ill.2d 166, 85 Ill.Dec. 322, 473 N.E.2d 921 (1984).

At the outset the court notes that 28 U.S.C. § 1738 directs federal courts to give state court orders the same effect such orders would be given by the courts of the state which rendered the order.4 Paine Webber, Inc., 870 F.2d at 1290; Jones v. City of Alton, Illinois, 757 F.2d 878, 883 (7th Cir.1985). Therefore, Illinois preclusion law will govern the effect to be given to the order denying the petition to vacate.

Under Illinois law, three elements must be met before collateral estoppel will apply. There must be a valid final judgment, the judgment must have actually decided the issue presented in the subsequent proceeding, and the party against whom estoppel is asserted must have been a party or in privity with a party to the prior litigation. Service Systems Corporation v. Van Bortel, 174 Ill.App.3d 412, 123 Ill.Dec. 833, 838, 528 N.E.2d 378, 383 (1988); Fearon v. Mobil Joliet Refining Corp., 131 Ill.App.3d 1, 86 Ill.Dec. 335, 475 N.E.2d 549 (1984); People v. Murphy, 102 Ill.App.3d 448, 58 Ill.Dec. 152, 430 N.E.2d 94 (1981).

The first essential element to the application of collateral estoppel is the presence of a final judgment. An order is considered final if it terminates the litigation between the parties and finally determines, fixes, and disposes of their rights as to the issues made by the suit. Gilbert v. Braniff International Corporation, 579 F.2d 411, 413 (7th Cir.1978). Furthermore, finality requires that the potential for appellate review has been exhausted. Ballweg v. City of Springfield, 114 Ill.2d 107, 102 Ill.Dec. 360, 362, 499 N.E.2d 1373, 1375 (1986); People v. Shlensky, 118 Ill.App.3d 243, 73 Ill.Dec. 854, 857, 454 N.E.2d 1103, 1106 (1983).

Illinois law provides by statute that an order denying a petition to vacate a default judgment is a final and appealable order. Ill.Rev.Stat. ch. 110A, ¶ 304(b)(3) (Supp. 1989).5 In addition, the denial of the petition to vacate was affirmed by the appellate court and denied further review by the Supreme Court. Thus, the potential for appellate review has been exhausted.

Secondly, the prior order must have actually decided the issue presented in the subsequent proceeding. Collateral estoppel is based on broad principles of justice and applies only when the party has had an opportunity to establish his claim. 23A Illinois Law & Practice, Judgments § 361 (1979).

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Related

People v. Shlensky
454 N.E.2d 103 (Appellate Court of Illinois, 1983)
People v. Murphy
430 N.E.2d 94 (Appellate Court of Illinois, 1981)
Telegraph Savings & Loan Ass'n v. Schilling
473 N.E.2d 921 (Illinois Supreme Court, 1984)
Fearon v. Mobil Joliet Refining Corp.
475 N.E.2d 549 (Appellate Court of Illinois, 1984)
Service Systems Corp. v. Van Bortel
528 N.E.2d 378 (Appellate Court of Illinois, 1988)
Ballweg v. City of Springfield
499 N.E.2d 1373 (Illinois Supreme Court, 1986)

Cite This Page — Counsel Stack

Bluebook (online)
104 B.R. 5, 1989 Bankr. LEXIS 1419, 1989 WL 99740, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-richey-ilsb-1989.