In the Matter of the Channahon Park District v. McCoy

2022 IL App (3d) 210267-U
CourtAppellate Court of Illinois
DecidedSeptember 29, 2022
Docket3-21-0267
StatusUnpublished

This text of 2022 IL App (3d) 210267-U (In the Matter of the Channahon Park District v. McCoy) 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 the Matter of the Channahon Park District v. McCoy, 2022 IL App (3d) 210267-U (Ill. Ct. App. 2022).

Opinion

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).

2022 IL App (3d) 210267-U

Order filed September 29, 2022

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

IN THE MATTER OF THE APPLICATION ) Appeal from the Circuit Court OF THE CHANNAHON PARK DISTRICT, A ) of the 12th Judicial Circuit, BODY POLITIC AND CORPORATE ) Will County, Illinois, ORGANIZED AND EXISTING UNDER THE ) LAWS OF THE STATE OF ILLINOIS, TO ) SELL A PARCEL OF LAND LESS THAN ) THREE ACRES IN AREA ) ) (Channahon Park District, ) Appeal No. 3-21-0267 ) Circuit No. 21-MR-391 Petitioner-Appellee, ) ) v. ) ) Jacob McCoy and George McCoy, ) ) Honorable John C. Anderson, Respondents-Appellants). ) Judge, Presiding.

JUSTICE HAUPTMAN delivered the judgment of the court. Justices McDade and Peterson concurred in the judgment.

ORDER ¶1 Held: The appeal is dismissed as moot under Illinois Supreme Court Rule 305(k) (eff. July 1, 2017) because the subject property passed to a nonparty pursuant to a final judgment and respondents did not perfect a stay within the time for filing the appeal.

¶2 The Channahon Park District (Park District) filed an application for the sale of property,

located in Will County, to Tobro Ltd. (Tobro) under section 1 of the Park Commissioners Land

Sale Act (Act) (70 ILCS 1235/1 (West 2020)). Jacob and George McCoy (McCoys), who also desired to purchase the subject property, objected to the sale. After a hearing, the circuit court

granted the Park District’s application for the sale of the subject property. The McCoys appealed

without perfecting a stay of the circuit court’s judgment. Thereafter, the Park District and Tobro

closed on the sale of the subject property and Tobro recorded its special warranty deed in Will

County. For the reasons discussed below, we dismiss this appeal as moot under Rule 305(k).

¶3 I. BACKGROUND

¶4 On September 28, 2020, the Board of Park Commissioners (Board) for the Park District

unanimously approved a resolution for the sale of a 2.27-acre parcel of property that was operated

as a skateboard park in Channahon, Illinois. For various reasons, the Board found the subject

property was not needed, necessary, or useful to the Park District. Therefore, the resolution stated

it was in the public interest to sell the subject property, subject to the approval of the circuit court.

¶5 Thereafter, the Park District solicited offers for the subject property. Tobro and George

McCoy submitted competing offers of $550,000 and $575,000, respectively. The Park District’s

attorney prepared a memorandum for the Board to weigh the pros and cons of the competing

offers, which were both above the appraised value of the subject property. The Park District’s

attorney ultimately concluded, “looking at the totality of the contracts and the likelihood that

each will be consummated, I find the Tobro contract offer to be preferable to the McCoy offer.”

¶6 On February 8, 2021, the Board unanimously approved a second resolution for the sale of

the subject property. The second resolution included provisions that were identical to those

contained in the first resolution. The second resolution also specifically approved the sale of the

subject property to Tobro, stating the subject property was to be sold according to the terms of an

attached real estate sale contract. The contract, which was executed on February 11, 2021,

2 provided for the sale of the subject property to Tobro for $550,000 and a deposit of $10,000 as

earnest money. The contract noted the circuit court had to approve the sale pursuant to the Act.

¶7 On February 16, 2021, the Park District filed an application for the sale of the subject

property in the circuit court under section 1. The Park District informed the circuit court that a

resolution was adopted on February 8, 2021, determining the subject property was not needed,

necessary, or useful to the Park District. Consistent with the public interest, the Park District

requested leave to sell the subject property under the terms of the contract executed with Tobro.

¶8 On March 11, 2021, the circuit court granted the McCoys leave to appear in the circuit

court. Thereafter, the circuit court scheduled a hearing on the Park District’s application for the

sale of the subject property for April 21, 2021. At that hearing, the circuit court received testimony

from George McCoy, who owned an automobile repair and towing service on a parcel of property

abutting the subject property. George testified about his offer to purchase the subject property,

communications with the Park District, and revisions to his initial offer after the Board approved

the sale of the subject property to Tobro. Christopher Caldwell, who was the acting president of

the Board when the sale of the subject property was approved, also testified at the hearing.

Caldwell described the Board’s consideration of the competing offers and the factors resulting in

its acceptance and approval of the Tobro offer over the McCoy offer. On May 27, 2021, the circuit

court granted the Park District’s application for the sale of the subject property to Tobro.

¶9 The McCoys filed a timely notice of appeal on June 22, 2021. On July 8, 2021, the Park

District and Tobro closed on the sale of the subject property. Tobro subsequently recorded its

special warranty deed in Will County on July 22, 2021.

¶ 10 Thereafter, on August 11, 2021, the Park District filed a motion to dismiss this appeal as

moot under Rule 305(k), arguing the circuit court’s judgment was final, the subject property was

3 sold to a nonparty, Tobro, and the McCoys never perfected a stay of the circuit court’s judgment.

The McCoys filed a response to the motion to dismiss on August 16, 2021, arguing they were not

directly seeking to affect the right, title, or interest of Tobro in the subject property. Instead, the

McCoys argued they were merely seeking compliance with the procedural requirements of the

Act. Our court denied the Park District’s motion to dismiss on August 17, 2021.

¶ 11 Approximately seven months later, on April 4, 2022, the McCoys filed a motion to remand

the case to the circuit court for an evidentiary hearing on a perceived conflict of interest between

Caldwell and Tobro. In the motion, which was filed under Illinois Supreme Court Rules 361 (eff.

Dec. 1, 2021) and 366(a)(5) (eff. Feb. 1, 1994), the McCoys argued Caldwell had an undisclosed

financial interest in the Tobro contract when he and the Board voted to approve that contract. The

Park District responded to the McCoys motion on April 6, 2022. On April 8, 2022, our court took

the McCoys’ motion and the Park District’s response with the case. We resolve that motion below.

¶ 12 II. ANALYSIS

¶ 13 On appeal, the McCoys attempt to challenge the circuit court’s decision to grant the Park

District’s application for the sale of the subject property under section 1, specifically requesting

that we “overturn the Court’s final order of May 27, 2021.” As support, the McCoys argue the

Park District violated the procedural requirements contained in section 1 and, by accepting Tobro’s

offer to purchase the subject property, failed to act in the public interest. The Park District responds

to each argument and reiterates its belief, under Rule 305(k), that the appeal is moot. For the

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