Ohiku v. Hernandez

2022 IL App (1st) 201365-U
CourtAppellate Court of Illinois
DecidedMarch 4, 2022
Docket1-20-1365
StatusUnpublished
Cited by1 cases

This text of 2022 IL App (1st) 201365-U (Ohiku v. Hernandez) 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
Ohiku v. Hernandez, 2022 IL App (1st) 201365-U (Ill. Ct. App. 2022).

Opinion

2021 IL App (1st) 201365-U No. 1-20-1365 Order filed March 4, 2021 Sixth Division

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 ______________________________________________________________________________ ESTHER OHIKU, ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Cook County. ) v. ) 18 CH 08001 ) JAVIER HERNANDEZ, LAKEVIEW EAST ) Honorable COOPERATIVE, and PENTIUK, COUVREUR, ) Alison Conlon, KOBILJAK, ) Judge, Presiding. ) Defendants-Appellees. )

JUSTICE SHARON ODEN JOHNSON delivered the judgment of the court. Presiding Justice Daniel Pierce and Justice Mary Mikva concurred in the judgment.

ORDER

¶1 Held: We affirm the judgment of the circuit court granting defendants’ motion for summary judgment when (1) plaintiff failed to file a motion to strike the supporting affidavit in order to make a timely challenge and (2) plaintiff cannot demonstrate that defendants failed to exercise due care.

¶2 Plaintiff Ester Ohiku appeals an order of the circuit court of Cook County granting

summary judgment in favor of Lakeview East Cooperative (LEC) and Javier Hernandez. On No. 1-20-1365

appeal, plaintiff contends that: (1) the affidavit submitted by Hernandez in support for summary

judgment was not proper under Illinois Supreme Court Rule 191(a) (Ill. S. Ct. R. 191(a) (eff. Jan.

4, 2013)) when it failed to lay a foundation of Hernandez’s personal knowledge and failed to attach

the relevant documents, and (2) the circuit court had insufficient evidence that defendants were

protected under the business judgment rule. For the following reasons, we affirm.

¶3 BACKGROUND

¶4 Plaintiff was a long-standing board member and former President of LEC. The Board of

Directors (the Board) of LEC received a report from the United States Department of Housing and

Urban Development (HUD)1 directing that plaintiff be removed from the Board upon its finding

that LEC was not her primary residence and she misused corporate assets for her benefit. Based

on HUD’s findings, on April 15, 2018, a petition for plaintiff’s removal and a request for a vote

thereon pursuant to Article II, section 2.122 of LEC’s bylaws was presented to the Board. On June

18, 2018, a special meeting was convened to vote on plaintiff’s removal and 107 registered

members were in attendance. The League of Women Voters (the League) were present to count

and oversee the vote. The League tallied the votes cast as follows: 66 were in favor of removal, 33

were opposed, one ballot was blank, and one had “abstain” written on it. The League determined

that, of the members that were present and voted, the affirmative votes met the threshold of two-

thirds as required by the LEC bylaws. 3 However, after voters objected to the two remaining ballots

(one blank and one abstention) not being included with the yes votes, Hernandez, the President of

1 The report was not provided in the record. 2 This rule sets forth the requirements of notification for there to be a special meeting called. 3 Although it was not specifically stated at the meeting, the League noted that this was in accordance with LEC’s bylaws and the language of “present and voted” is consistent with Article III, section 3.4 of LEC’s bylaws. -2- No. 1-20-1365

the Board, announced that everything would be reviewed and “in seven days we will get the

results.”

¶5 On June 22, 2018, Pentiuk, Couvreur, and Kobiljak (PCK), counsel for LEC, sent a letter

to the Board and members of LEC, informing them that PCK was present at the special meeting

regarding plaintiff’s removal, and that while the League was present to count and oversee the vote,

the league needed additional time to determine how to treat the two disputed ballots. Nevertheless,

after seven days the League declined to render a decision and deferred the matter to the Board and

PCK. The Board then deferred to PCK, who determined that neither of the two disputed votes

qualified as votes cast, therefore, the vote to remove plaintiff passed. PCK noted that it based its

findings on the applicable bylaws, relevant Illinois law, Robert’s Rules of Parliamentary Procedure

(Robert’s Rules) 4, and consultation with independent parliamentary resources. 5

¶6 On July 16, 2018, plaintiff filed a pro se amended motion for a preliminary injunction to

bar defendants from removing her as a member of the Board. Plaintiff maintained that PCK

wrongly concluded that a two-thirds vote in favor of removal occurred when it counted two ballots

that should not have been counted. Plaintiff argued that monetary damages could not be an

adequate remedy at law for her role on the Board.

¶7 On August 1, 2018, plaintiff filed an additional pro se injunction against Hernandez, LEC,

and PCK. This time, plaintiff argued that defendants did not have the requisite two-thirds

affirmative votes and asked the circuit court to intervene to prevent defendants from succeeding

in implementing their “arbitrary maneuver” to remove her.

4 Its proper title is Robert’s Rules of Order, and we will continue to reference it as Robert’s Rules to avoid confusion. Robert’s Rules has had many authors, editions and publishers; therefore, we decline to cite to a specific one since the parties do not. 5 In this letter, counsel does not provide specific citations or codes. -3- No. 1-20-1365

¶8 On October 19, 2018, PCK filed a motion to dismiss pursuant to section 2-615 (735 ILCS

5/2-615 (West 2018)) of the Illinois Code of Civil Procedure arguing that plaintiff could not

substantiate any set of facts that would prove her case against them. PCK argued that they were

only present to represent LEC and ensure that the voting and hearing process for removal of a

director was properly conducted. PCK maintained that it did not tally the votes and did not

represent any single member of the Board. PCK argued that plaintiff failed to state a claim for

breach of fiduciary duty or legal malpractice because there was no extra-contractual duty that was

owed to plaintiff by PCK. On February 25, 2019, the circuit court granted PCK’s motion, and they

were dismissed from the action.6

¶9 On April 1, 2019, LEC filed a motion for summary judgment arguing that the Board was

entitled to take advice from PCK in reaching its decision and exercising due care. In so doing, as

Hernandez attested to in his affidavit, a director has to inform themselves of material facts

necessary to properly exercise their business judgment.

¶ 10 On June 10, 2019, plaintiff filed a motion for summary judgment arguing that LEC failed

to obtain the necessary affirmative votes required to remove her from the Board. Plaintiff

maintained that Article III, section 3.4 of LEC’s bylaws provided that any director may be removed

upon two-thirds of the “votes present and voted” at a convened meeting where at least 35% of the

members were present. Plaintiff argued that an affirmative vote was not required and the two

ballots in question should have counted toward the opposed votes citing Prosser v. Village of Fox

Lake, 91 Ill. 2d 389, 395 (1982) as support.

¶ 11 On June 26, 2019, plaintiff retained her own attorney and filed a response to LEC’s motion

for summary judgment arguing that defendants failed to make a prima facie case that they would

6 Going forward, defendants will consist of Hernandez and LEC.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Ohiku v. Hernandez
2022 IL App (1st) 201365-U (Appellate Court of Illinois, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2022 IL App (1st) 201365-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ohiku-v-hernandez-illappct-2022.