Kuykendall v. City of Park Ridge

2025 IL App (1st) 241551-U
CourtAppellate Court of Illinois
DecidedDecember 11, 2025
Docket1-24-1551
StatusUnpublished

This text of 2025 IL App (1st) 241551-U (Kuykendall v. City of Park Ridge) 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
Kuykendall v. City of Park Ridge, 2025 IL App (1st) 241551-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 241551-U Fourth Division Filed December 11, 2025 No. 1-24-1551

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

) LISA KUYKENDALL, Appeal from the ) Petitioner-Appellant, ) Circuit Court of Cook County ) v. No. 2024 CH 00871 ) THE CITY OF PARK RIDGE, ) The Honorable Neil H. Cohen, ) Judge, presiding. Respondent-Appellee. )

JUSTICE OCASIO delivered the judgment of the court. Presiding Justice Navarro and Justice Quish concurred in the judgment.

ORDER

¶1 Held: The petition for a declaratory judgment was properly dismissed because it did not allege facts showing that there was an actual controversy ripe for judicial adjudication, but the dismissal should have been without prejudice.

¶2 This case concerns four water and sewer pipes that connect 24 townhouses in Park Ridge,

Illinois, to the main city pipes. The petitioner, Lisa Kuykendall, owns one of those townhouses.

She believes that the respondent, the City of Park Ridge, is responsible for maintaining, repairing,

and replacing the shared pipes, and she filed a petition in the circuit court seeking a declaratory

judgment to that effect. The City moved to dismiss on the basis that Kuykendall lacked standing.

The circuit court granted the motion and dismissed the petition. While we agree that Kuykendall’s

petition did not show that there was an actual controversy ripe for resolution via declaratory relief, No. 1-24-1551

we find that it was error to dismiss with prejudice. We therefore affirm the judgment but modify it

to be without prejudice.

¶3 I. BACKGROUND

¶4 In the 1960s, a developer built a six-building, 24-unit townhouse complex on a parcel of land

at the corner of Northwest Highway and Delphia Avenue in Park Ridge. It appears from materials

attached to the petition that the parcel was divided entirely into 24 “dwelling parcels” and 24

associated “parking parcels.” The developer granted perpetual easements for water, gas, telephone,

electricity, and ingress and egress to be “used in common” by anybody with an interest in one of

the townhouses. The declaration of easements also provided that any other facilities serving more

than one unit that already existed or might be installed later would be “perpetually used in

common” by the owners or occupants of the parcels that used those facilities. There were no

provisions made for a homeowner or condo association, which remains the situation to date.

¶5 In addition to the townhouses and a parking lot, the site plans called for two new eight-inch

sewer pipes and two new three-inch water mains to be installed under the land between or next to

the buildings. The plans show individual connections running from the three-inch pipe to each of

the 24 townhomes, and Kuykendall’s petition alleges that each townhouse has its own water meter

and “buffalo box” (a term that refers to a type of housing used for shut-off valves that can be

accessed from ground level). Further, the developer applied to the Metropolitan Sanitary District of Greater Chicago for a permit to construct two eight-inch sanitary sewer services and connect

them to the existing twelve-inch main sewer line under Northwest Highway. The application was

signed by the developer’s president and by K.C. Cunningham, the director of public works for the

City of Park Ridge. The permit, which was approved in 1963, listed the City as the permittee and

provided that the system would “be constructed, maintained, and operated at the sole cost of the

Permittee.” 1

1 The copy of the permit that Kuykendall attached to her petition was not signed by anybody from the City, but the petition alleges that the sewers were built “[p]ursuant to the permit.” That allegation is

-2- No. 1-24-1551

¶6 Sixty years later, Kuykendall, who owns one of the 24 units, learned from her plumber that

her unit was at the end of one of the shared sewer lines. She contacted the City to ask about

maintaining, repairing, and replacing the sewer pipe. The City responded that it was not

responsible for the sewer system, citing a 1975 policy statement providing that the City generally

will not maintain street, water, or sewer facilities on private property. Kuykendall then filed the

underlying petition for declaratory judgment seeking a declaration that “the City of Park Ridge is

responsible for the maintenance, operation, repair or replacement of the sanitary sewer system and

water mains servicing the Development.”

¶7 The City filed a combined motion to dismiss under section 2-619.1 of the Code of Civil

Procedure (735 ILCS 5/2-619.1 (West 2022)). In the portion of the motion it designated as having

been brought under section 2-615 (id. § 2-615), the City identified two grounds for dismissal. 2 First, the City argued that Kuykendall lacked “standing to bring an action for declaratory relief”

because the petition did not allege facts showing the existence of an “actual controversy” and

because Kuykendall was “not an interested party.” Second, the City argued that any controversy

was not ripe for adjudication, noting the absence of “any indication of a need” for repair or

replacement and contending that the petition did not set forth adequate factual detail demonstrating

that withholding consideration would impose a hardship on Kuykendall.

¶8 After briefing, the circuit court sua sponte recharacterized the motion to dismiss for lack of

standing as a section 2-619 (id. § 2-619) motion and, agreeing that Kuykendall lacked standing,

dismissed the petition with prejudice. Kuykendall appeals.

treated as true for the purposes of a motion to dismiss. See Cahokia Unity School District No. 187 v. Pritzker, 2021 IL 126212, ¶ 24. 2 The City also moved to dismiss under section 2-619(a)(9) (735 ILCS 5/2-619(a)(9) (West 2022)), arguing that it “owe[d] no duty” to Kuykendall under the public-duty rule and that declaratory relief was not proper because it would simply be a declaration. The circuit court did not address either argument, and the City does not raise those arguments on appeal.

-3- No. 1-24-1551

¶9 II. ANALYSIS

¶ 10 We begin by noting the procedural confusion surrounding the dismissal of Kuykendall’s

petition. In the circuit court, the City brought a combined motion to dismiss under both sections

2-615 and 2-619. In the combined motion, the City designated both its standing and ripeness

arguments as challenges to the legal sufficiency of the petition under section 2-615. When it ruled

on the motion, the circuit court found that lack of standing was an affirmative defense that should

have been raised as a basis for involuntary dismissal under section 2-619, so it treated that section

of the motion as having been brought under section 2-619 and then granted that recharacterized

motion to dismiss.

¶ 11 On appeal, Kuykendall argues that the circuit court’s handling of the motion to dismiss was

procedurally improper. Among other things, she contends that the sua sponte recharacterization

denied her the opportunity to respond and that the court did not hold the City to the evidentiary

burden generally required of the moving party under section 2-619. We do not need to reach these

arguments. A trial court’s ruling on a combined motion to dismiss is reviewed de novo.

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Bluebook (online)
2025 IL App (1st) 241551-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kuykendall-v-city-of-park-ridge-illappct-2025.