O'Banner v. McDonald's Corporation

CourtIllinois Supreme Court
DecidedMay 31, 1996
Docket79547
StatusPublished

This text of O'Banner v. McDonald's Corporation (O'Banner v. McDonald's Corporation) is published on Counsel Stack Legal Research, covering Illinois Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
O'Banner v. McDonald's Corporation, (Ill. 1996).

Opinion

NOTICE: Under Supreme Court Rule 367 a party has 21 days after the filing of

the opinion to request a rehearing. Also, opinions are subject to

modification, correction or withdrawal at anytime prior to issuance of the

mandate by the Clerk of the Court. Therefore, because the following slip

opinion is being made available prior to the Court's final action in this

matter, it cannot be considered the final decision of the Court. The official

copy of the following opinion will be published by the Supreme Court's

Reporter of Decisions in the Official Reports advance sheets following final

action by the Court.

                 Docket No. 79547--Agenda 11--January 1996.

 REGINALD O'BANNER, Appellee, v. McDONALD'S CORPORATION et al. (McDonald's

                          Corporation, Appellant).

                        Opinion filed May 31, 1996.

    JUSTICE HARRISON delivered the opinion of the court:

    Reginald O'Banner brought an action in the circuit court of Cook County

to recover damages for personal injuries he allegedly sustained when he

slipped and fell in the bathroom of a McDonald's restaurant. In his

complaint, O'Banner named as defendants McDonald's Corporation (McDonald's)

and certain "unknown owners." See 735 ILCS 5/2--413 (West 1994). McDonald's

promptly moved for summary judgment on the grounds that the restaurant was

actually owned by one of its franchisees and that it neither owned, operated,

maintained, nor controlled the facility.

    After initially denying McDonald's motion, the circuit court granted

summary judgment in favor of the company and made an express written finding

that there was no just reason to delay an appeal. 155 Ill. 2d R. 304(a). The

appellate court subsequently reversed and remanded, with one justice

dissenting. 273 Ill. App. 3d 588. We granted McDonald's petition for leave to

appeal (155 Ill. 2d R. 315) and have allowed Amoco Oil Company, Burger King,

the Illinois Association of Defense Trial Counsel and the Illinois Trial

Lawyers Association to file briefs as friends of the court (155 Ill. 2d R.

345). For the reasons that follow, we now reverse and remand to the circuit

court.

    Before addressing the substantive issues before us, we note, as did the

appellate court, that there has been some confusion as to the basis for

appellate review. The appellate court realized that the circuit court had

entered a written finding under Rule 304(a) (155 Ill. 2d R. 304(a)), which

governs final judgments as to fewer than all parties or claims, but it did

not understand the purpose for such a finding. It believed that appellate

jurisdiction was proper only under Rule 301 (155 Ill. 2d R. 301), which

pertains to final judgments that dispose of an entire proceeding.

    What the appellate court overlooked was that McDonald's was not the only

defendant named in O'Banner's complaint. As we have previously indicated,

O'Banner named "unknown owners" as well. The "unknown owners" were not

involved in McDonald's motion for summary judgment, and the circuit court's

order granting McDonald's motion did not affect the continued viability of

O'Banner's claims against these remaining defendants. Accordingly, the

circuit court's order did not dispose of the entire proceeding and an appeal

could not have been brought under Rule 301. Because summary judgment was

granted to fewer than all of the defendants, the only basis for an immediate

appeal was under Rule 304(a). McDonald's itself clearly appreciated this, for

its summary judgment motions consistently included a request for entry of the

requisite Rule 304(a) findings.

    Although O'Banner's notice of appeal invoked Rule 301 rather than Rule

304(a), that mistake is of no consequence. Nothing in our rules requires a

notice of appeal to even mention whether review is sought under Rule 301 or

304(a). What is important is that the notice specify "the judgment or part

thereof or other orders appealed from and the relief sought from the

reviewing court" (155 Ill. 2d R. 303(b)(2)) so that the successful party is

advised of the nature of the appeal (see Burtell v. First Charter Service

Corp., 76 Ill. 2d 427, 433-34 (1979)). There is no question that this

requirement was satisfied here. Accordingly, O'Banner's citation to the wrong

rule was nothing more than harmless surplusage. His notice of appeal was

sufficient to invoke the appellate court's jurisdiction.

    The substantive issue before the appellate court, and the question which

concerns us today, is whether the circuit court erred in granting McDonald's

motion for summary judgment. Under section 2--1005(c) of the Code of Civil

Procedure (735 ILCS 5/2--1005(c) (West 1994)), a party is entitled to summary

judgment

         "if the pleadings, depositions, and admissions on file, together

         with the affidavits, if any, show that there is no genuine issue as

         to any material fact and that the moving party is entitled to

         judgment as a matter of law."

In applying this statute, the court must construe the pleadings, depositions

and affidavits strictly against the moving party and liberally in favor of

the opponent. Although use of the summary judgment procedure can be an

efficient means for disposing of certain lawsuits, it is a drastic measure

that should be employed only when the right of the moving party is clear and

free from doubt. Loyola Academy v. S&S Roof Maintenance, Inc., 146 Ill. 2d

263, 271 (1992).

    The circuit court here entered summary judgment in favor of McDonald's

based on the company's argument that it was merely the franchisor of the

restaurant where O'Banner was injured and, as such, had no responsibility for

the conditions that caused his accident. O'Banner challenged this conclusion

in the appellate court by theorizing that even though McDonald's was a

franchisor, it could nevertheless be held liable for the franchisee's

negligence under principles of respondeat superior because there was

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