McArdle v. Christensen

2019 IL App (3d) 170858
CourtAppellate Court of Illinois
DecidedSeptember 26, 2019
Docket3-17-0858
StatusUnpublished

This text of 2019 IL App (3d) 170858 (McArdle v. Christensen) 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
McArdle v. Christensen, 2019 IL App (3d) 170858 (Ill. Ct. App. 2019).

Opinion

2019 IL App (3d) 170858

Opinion filed September 25, 2019 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

PHILLIP McARDLE, as Successor Trustee of ) Appeal from the Circuit Court the Barbara M. McArdle Trust, ) of the 13th Judicial Circuit, ) Grundy County, Illinois. Plaintiff-Appellee, ) ) and ) ) Appeal No. 3-17-0858 TAD CHRISTENSEN, as Trustee of the ) Circuit No. 17-CH-69 Raymond H. Christensen Irrevocable Trust and ) as Trustee of the Beverly J. Christensen ) Irrevocable Trust, ) ) The Honorable Defendant-Appellant. ) Lance R. Peterson, ) Judge, presiding. ___________________________________________________________________________

JUSTICE McDADE delivered the judgment of the court, with opinion. Presiding Justice Schmidt and Justice O’Brien concurred in the judgment and opinion.

____________________________________________________________________________

OPINION

¶1 After a real estate purchase agreement failed to close, the plaintiff, Phillip McArdle

(McArdle), in his capacity as trustee of the Barbara M. McArdle Trust (McArdle Trust), filed a

breach of contract and quiet title action against Tad Christensen (Christensen) in his

representative capacity as trustee of the Raymond H. Christensen Trust and Beverly J.

Christensen Trust (collectively, Christensen Trusts). A summons was issued, and substitute service was completed at the address held out on earnest-money checks as that of the two

Christensen Trusts. Christensen neither appeared nor responded, and a default judgment was

entered. Christensen filed a motion to quash service of process, alleging that he was not properly

served and that the circuit court never obtained personal jurisdiction over him. The circuit court

disagreed and denied the motion; Christensen appealed.

¶2 I. BACKGROUND

¶3 On January 28, 2015, the McArdle Trust, through McArdle as trustee, entered into a

contract to sell a 31.53-acre parcel of unimproved agricultural land to the Beverly J. Christensen

Trust, through Christensen as trustee, for $197,063. Christensen did not list an address beneath

his signature on the contract although a line was provided for that purpose. He did, however, sign

two separate checks, one from each of the Christensen Trusts, each in the amount of $5000. Each

check listed the address of the issuing trust as 7339 W. 154th Place, Orland Park, Illinois. More,

specifically, the following information was printed in the upper left hand corners of the checks:

“Raymond H. Christensen Irrevocable Trust

Tad Christensen TRTEE

U/A 08/19/2003

7339 W. 154th Pl.

Orland Park, IL 60462”

“Beverly J. Christensen Irrevocable Trust

2 Orland Park, IL 60462”

¶4 The sale was contingent upon the McArdle Trust obtaining a building permit, which

required that the McArdle Trust have the property rezoned from agricultural to agricultural

residential. In May 2015, the McArdle Trust was able to secure the rezoning. The closing date

for the sale was eventually set for June 9, 2015.

¶5 No one appeared at closing from the Beverly J. Christensen Trust. It was not until

September 9, 2015, that the attorney for the McArdle Trust was advised by letter from an

attorney that the Beverly J. Christensen Trust was cancelling the sale due to alleged title

deficiencies and was demanding the return of the earnest money. Plaintiffs refused to return the

earnest money asserting the defendant was in breach and plaintiff would retain the earnest money

pending an alternate sale.

¶6 The McArdle Trust relisted the property and eventually sold it at an auction for a reduced

price. At the closing of that sale, the McArdle Trust learned that the Beverly J. Christensen Trust

had placed a lien on the property, resulting in its loss of the sale.

¶7 Due to the failed sale, McArdle, as trustee of the McArdle Trust, filed a civil complaint

against Christensen as trustee of the two Christensen Trusts. The complaint alleged breach of

contract and sought to quiet title to the subject property.

¶8 Separate summons named Christensen, as trustee of each trust, at the aforementioned

Orland Park address. Each affidavit of service stated that substitute service was executed on

Beverly Buckley, 1 a 65-year-old white female, at that address on June 26, 2017. Each affidavit

also recited that the Cook County Sheriff’s deputy effecting service had informed Beverly

1 Buckley is alleged to be the mother of Tad Christensen, the owner of the Beverly J. Christensen Irrevocable Trust, and the beneficiary of the Raymond H. Christensen Irrevocable Trust. 3 Buckley of the contents of the summons and had mailed a copy of the summons to the defendant

at that same address.

¶9 After Christensen failed to respond to the complaint, McArdle filed a motion for default

judgment. The circuit court granted that motion on September 1, 2017, after a hearing.

¶ 10 Christensen subsequently filed a motion to quash the service of process. His motion

alleged that he had never resided at the address listed on the summons; rather, he lived with his

girlfriend at 1900 Darien Club Road in Darien, Illinois. In response, McArdle argued that

Christensen was not being sued in his individual capacity, so personal service on him was

irrelevant. Rather, McArdle was suing the Christensen Trusts, which had the aforementioned

Orland Park address of record.

¶ 11 The circuit court held a hearing on the motion to quash on December 8, 2017. In denying

the motion, the court ruled that the trust was being sued in a representative capacity and that the

proper place to serve the summons was at the trust’s principal place of business.

¶ 12 Christensen appealed.

¶ 13 II. ANALYSIS

¶ 14 On appeal, Christensen argues that the circuit court erred when it denied his motion to

quash service of process. Specifically, he argues that McArdle was required to serve him at his

residence—i.e., under the provision of the Code of Civil Procedure (Code) addressing service of

process on individuals (735 ILCS 5/2-203 (West 2016))—and that the failure to do so prevented

the court from obtaining personal jurisdiction over him.

¶ 15 A judgment rendered without both personal jurisdiction over the parties and subject-

matter jurisdiction over the litigation is void and can be attacked at any time. State Bank of Lake

Zurich v. Thill, 113 Ill. 2d 294, 308-09 (1986). The question of whether a circuit court obtained

4 personal jurisdiction over a party is a question of law that we review de novo. In re Dar. C., 2011

IL 111083, ¶ 60.

¶ 16 Personal jurisdiction can be obtained either through a general appearance by the party or

service of process according to statute. Thill, 113 Ill. 2d at 308. One manner in which service of

process can be completed is through the use of a summons. Thill, 113 Ill. 2d at 308. Notably, the

process provisions of the Code do not provide specific service requirements related to the type of

trusts and trustees that are involved in this case. See 735 ILCS 5/2-201 to 2-213 (West 2016).

Accordingly, the parties dispute which provision should apply to the service attempted on

Christensen. Christensen claims the provision related to service on individuals should apply.

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Related

Sullivan v. Kodsi
836 N.E.2d 125 (Appellate Court of Illinois, 2005)
Hanley v. Kusper
337 N.E.2d 1 (Illinois Supreme Court, 1975)
State Bank of Lake Zurich v. Thill
497 N.E.2d 1156 (Illinois Supreme Court, 1986)
In re Dar. C.
2011 IL 111083 (Illinois Supreme Court, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
2019 IL App (3d) 170858, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcardle-v-christensen-illappct-2019.