SBC Waste Solutions, Inc. v. Flood

2025 IL App (3d) 240511-U
Appellate Court of Illinois·Decided September 2, 2025·No. 3-24-0511·Unpublished

Opinion

NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule 23(e)(1).

2025 IL App (3d) 240511-U

Order filed September 2, 2025 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

SBC WASTE SOLUTIONS, INC., ) Appeal from the Circuit Court ) of the 18th Judicial Circuit, Plaintiff-Appellee, ) Du Page County, Illinois. ) v. ) Appeal No. 3-24-0511 ) Circuit No. 20-L-90 CHRISTOPHER FLOOD, ) ) The Honorable Defendant-Appellant. ) Bonnie M. Wheaton and Bryan S. ) Chapman, ) Judges, Presiding. ____________________________________________________________________________

JUSTICE ANDERSON delivered the judgment of the court. Justices Hettel and Bertani concurred in the judgment. ____________________________________________________________________________

ORDER

¶1 Held: The trial court erred in finding that the plaintiff offered sufficient facts to avoid dismissal under section 2-615 (735 ILCS 5/2-615 (West 2020)) because we hold that the dissenter’s rights provisions of the Illinois Business Corporation Act of 1983 (805 ILCS 5/11.65, 11.70 (West 2020)) are inapplicable here. We reverse the denial of the motion to dismiss and remand the cause to the trial court.

¶2 In relevant part, the plaintiff filed a complaint seeking relief under the dissenter’s rights

provisions of the Illinois Business Corporation Act of 1983 (805 ILCS 5/11.65, 11.70 (West

2020)). The defendant filed a motion seeking partial dismissal of the complaint pursuant to section 2-615 (735 ILCS 5/2-615 (West 2020)). He argued that the plaintiff was not entitled to the relief

requested because it failed to fulfill the statutory requirements in the Act. The trial court denied

the motion, finding that the complaint alleged sufficient facts to create a factual question about

whether it alleged a valid demand for dissenter’s rights relief under the Act. We reverse the denial

of the motion to dismiss and remand the cause to the trial court for further proceedings.

¶3 I. BACKGROUND

¶4 In January 2020, the plaintiff, SBC Waste Solutions, Inc., filed a replevin action in the Du

Page County circuit court, seeking to recover three garbage trucks from defendant Christopher

Flood. An evidentiary hearing was held, and the trial court found that SBC was the equitable owner

of the trucks. SBC filed an amended complaint in June 2020, adding Count III, which sought

recovery of Flood’s minority shares in the corporation under sections 11.65 and 11.70 of the Act

(805 ILCS 5/11.65, 11.70 (West 2020)). Citing section 11.65, SBC claimed that Flood’s dissent

from a corporate action triggered its right to purchase his shares. Later that month, SBC sought the

appointment of an appraiser to assess the fair value of Flood’s corporate shares as part of the

dissenter’s right action.

¶5 Flood answered the amended complaint and made two additional filings. In one of those

two filings, he sought dismissal of Count III under section 2-615 of the Code of Civil Procedure

(735 ILCS 5/2-615 (West 2020)). He argued that the count should be dismissed with prejudice

because SBC had failed to assert qualifying corporate action under section 11.65 of the Act and

failed to fulfill the procedural requirements mandated in section 11.70. Flood also filed a response

opposing SBC’s motion to appoint an appraiser to determine the fair value of his shares, again

arguing that SBC failed to assert the statutory prerequisites needed to obtain control of his minority

2 shares. On September 1, 2020, the trial court denied Flood’s motion to dismiss under section 2-

615 and continued SBC’s motion to appoint an appraiser.

¶6 As requested by the trial court, the parties submitted lists of proposed appraisers in early

2021. Discovery issues arose between the parties, and SBC filed a motion to confirm that the

appraiser would value Flood’s shares as of May 31, 2019, and to clarify the trial court’s February

3, 2021, order to establish that no subsequent business records would be discoverable. Flood

countered that the date selected was incorrect. On May 10, 2021, the trial court granted SBC’s

motion and clarified its discovery order, setting May 31, 2019, as the date to be used for valuing

Flood’s shares.

¶7 An appraiser was appointed pursuant to section 11.70 of the Act (805 ILCS 5/11/70(g)

(West 2020)), and he submitted a report dated September 18, 2023. That report set “the fair value

of a 1% equity interest in SBC Waste Solutions, Inc., as of May 31, 2019” at $9,800. An

evidentiary trial on the value of Flood’s shares was set to begin on April 24, 2024, and, with the

exception of deposing the appraiser, no further discovery was allowed. The hearing on the value

of Flood’s shares was subsequently continued.

¶8 The trial court directed the parties to submit written closing arguments. In its submission,

Flood argued that the appraiser’s valuation of his shares was inaccurate because SBC had provided

incomplete information and the appraiser had used improper valuation methods. The parties relied

on conflicting evidence from copies of handwritten notes on certain stock certificates to argue that

Flood owned either 5 or 10 shares of SBC stock.

¶9 The trial court entered its written ruling on July 18, 2024. It found that “as of the date of

Valuation, Chris Flood owned five shares of SBC stock, representing 5% of the total shares” and

adopted the appraiser’s valuation of $9,800 per share, making the total value of Flood’s shares on

3 May 31, 2019, $49,000. The court also ordered Flood to pay half of the court-appointed appraiser’s

fee, reducing his award by $25,088.91. The award was further reduced by just over $14,000 to

account for damages owed to SBC on its replevin claim. Flood filed a timely notice of appeal.

¶ 10 II. ANALYSIS

¶ 11 On appeal, Flood raises numerous issues. We first address whether the trial court

erroneously denied Flood’s motion to dismiss Count III of SBC’s amended complaint pursuant to

section 2-615 (735 ILCS 5/2-615 (West 2020)). Flood’s motion to dismiss argued that SBC failed

to fulfill the requirements needed to create dissenter’s rights and obtain relief pursuant to sections

11.65 (805 ILCS 5/11.65 (West 2020)) and 11.70 (805 ILCS 5/11.70 (West 2020)) of the Act.

¶ 12 A motion to dismiss brought under section 2-615 challenges a complaint’s legal sufficiency

by asserting that the allegations fail to provide a sufficient factual basis for the cause of action.

Dismissal is proper under section 2-615 when, construing the facts in the light most favorable to

the plaintiff, “it is clearly apparent that no set of facts can be proved that would entitle the plaintiff

to recovery.” Project44, Inc. v. FourKites, Inc., 2024 IL 129227, ¶ 18. We review a ruling on a

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