Spears v. City of Venice

2025 IL App (5th) 240847-U
CourtAppellate Court of Illinois
DecidedJune 23, 2025
Docket5-24-0847
StatusUnpublished

This text of 2025 IL App (5th) 240847-U (Spears v. City of Venice) 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
Spears v. City of Venice, 2025 IL App (5th) 240847-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (5th) 240847-U NOTICE Decision filed 06/23/25. The This order was filed under text of this decision may be NO. 5-24-0847 Supreme Court Rule 23 and is changed or corrected prior to not precedent except in the the filing of a Petition for IN THE limited circumstances allowed Rehearing or the disposition of under Rule 23(e)(1). the same. APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

YOLANDA SPEARS, ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Madison County. ) v. ) No. 24-SC-13 ) THE CITY OF VENICE, ) Honorable ) Ronald S. Motil, Defendant-Appellee. ) Judge, presiding. ______________________________________________________________________________

JUSTICE VAUGHAN delivered the judgment of the court. Presiding Justice McHaney and Justice Sholar concurred in the judgment.

ORDER

¶1 Held: The circuit court’s judgment is affirmed where insufficient evidence was presented at trial, arguments and evidence were improperly raised in plaintiff’s requested reconsideration, and argument raised on appeal was forfeited.

¶2 Plaintiff, Yolanda Spears, filed a complaint against the City of Venice, seeking damages

for the alleged wrongful towing of her vehicle and imposition of a fee to release the vehicle to her.

Following a bench trial, the court entered judgment against Spears. Spears now appeals from the

denial of her motion to reconsider. For the following reasons, we affirm.

¶3 I. BACKGROUND

¶4 On January 4, 2024, Spears filed a small claims complaint against the City of Venice (City).

Therein, Spears alleged that the City illegally towed her car and charged her an unauthorized tow

release fee. She also sought $10,000 in damages for mental distress caused by having to speak

1 with disrespectful people. The court held a bench trial on April 17, 2024. Spears appeared pro se

and testified on her own behalf.

¶5 Spears testified that she parked her car at her aunt’s house when Kevin Knox, a detective

for the City of Venice, pulled up and told her that her license plate was expired and he had to tow

her car. She told him that the car was parked and was not being moved. Detective Knox called

Chief of Police Antonio White, who arrived and also informed her that the car would be towed.

Spears further testified that, after the vehicle was towed, she had to pay the City a $250 tow release

fee and the towing company a storage fee of $50 for each day that the vehicle remained in the tow

yard. Spears eventually paid these fees, and the car was returned to her.

¶6 Spears claimed that she later learned that the City did not have a tow fee ordinance, so

she tried to get the $250 fee she paid back from the City. She testified that she attended a meeting

of the city council, where she allegedly learned that the mayor told the chief of police not to charge

tow fees, and the City was supposed to return money to individuals who were previously charged

these fees. Spears claimed that she ultimately paid $250 to the City for the release fee and $850 to

the towing company for the storage fee; she argued that the storage fee grew because she had to

pay the City first, and it took her additional days to acquire enough money. She told the court that

she was seeking $10,000, which included additional money for mental distress over how she

had been treated by various City officials and employees throughout the ordeal.

¶7 Prior to the City’s cross-examination, the court realized that Spears had not been sworn in,

and so this was done at that time. Counsel for the City asked Spears whether the mayor told her at

this city council meeting that her tow fee would be refunded. She responded that the mayor had

wanted her to sit down, and what he actually said was “whatever you want we will give it to

you.” Detective Knox then testified on behalf of the City, stating that he initiated a traffic stop of

2 Spears’s vehicle because the registration tags were expired. She pulled into a parking spot, he

got out of his car to let her know the purpose of the stop, and her car was ultimately towed.

¶8 The court inquired whether the City of Venice had a tow ordinance. Spears again asserted

that it did not but was collecting money regardless. Counsel for the City argued that there was

currently a tow ordinance in place, but he could not speak as to when it had been passed. Counsel

further argued that the burden was on the plaintiff to show that there was not a valid tow ordinance

in effect on the date that her vehicle was towed.

¶9 The court initially stated that it would take the matter under advisement but ultimately

issued a ruling in favor of the City, finding that Spears had not satisfied her burden of proof. The

court explained to Spears that it was “not going to establish a preceden[t] where residents who do

not agree with a valid police stop then file small claims cases because they don’t like how they

were talked to or whether or not there was a proper response made.” It further explained that it did

not have enough information to render a judgment in her favor.

¶ 10 On May 16, 2024, Spears filed a motion for leave to file an amended complaint, seeking to

add additional defendants and claims. She also filed a motion to vacate the court’s April 17, 2024,

judgment. The circuit court denied her motion to file an amended complaint, stating in its order

that the case was previously heard before the court, with arguments and evidence presented at that

time. The court stated that it would consider the motion to vacate as a motion for reconsideration

and set the matter for hearing.

¶ 11 Following a hearing on June 26, 2024, the circuit court entered an order denying Spears’s

motion to reconsider. This appeal followed.

3 ¶ 12 II. ANALYSIS

¶ 13 On appeal, Spears argues that both the City and the circuit court were aware that while

there is currently a tow fee ordinance in place in the City of Venice, there was no such ordinance

in effect on the date of her traffic stop. She further alleges that the circuit court heard testimony

that the police chief had been illegally collecting tow fees for years, and that counsel for the

City could not say when a tow ordinance was passed but admitted that the mayor offered Spears

a refund.

¶ 14 She claims that the circuit court erred in placing the burden of proof on her to show that no

valid tow ordinance existed, because the burden of proof was on the City pursuant to section 1-2-

6 of the Illinois Municipal Code (65 ILCS 5/1-2-6 (West 2024)). She further argues that the court

erred in failing to swear her in until after she had given most of her testimony. Lastly, she argues

that the court’s rulings against her at trial and on her motion to reconsider were in error, because

the court: (1) did not consider her testimony at trial, because it said it would take the matter under

advisement but then ruled against her; (2) ignored evidence of the mayor’s “fraudulent conduct”

and the City’s counsel’s ignorance of the City’s ordinances; (3) denied her request to have a court

reporter at the hearing on her motion to reconsider and other posttrial motions; (4) did not allow

her to present testimony on City ordinances from the City comptroller at the posttrial motions

hearing; and (5) did not consider new evidence she wished to submit at that hearing.

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2025 IL App (5th) 240847-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spears-v-city-of-venice-illappct-2025.