Washington v. Flash Aquisitions, LLC

2021 IL App (1st) 190325-U
CourtAppellate Court of Illinois
DecidedFebruary 26, 2021
Docket1-19-0325
StatusUnpublished

This text of 2021 IL App (1st) 190325-U (Washington v. Flash Aquisitions, LLC) 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
Washington v. Flash Aquisitions, LLC, 2021 IL App (1st) 190325-U (Ill. Ct. App. 2021).

Opinion

2020 IL App (1st) 190325-U

FIFTH DIVISION Order filed: February 26, 2021

No. 1-19-0325

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). ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

FIRST DISTRICT ______________________________________________________________________________

DEBRA WASHINGTON, ) Appeal from the ) Circuit Court of Plaintiff-Appellant and Cross-Appellee, ) Cook County. ) v. ) No. 17 L 4321 ) FLASH ACQUISITIONS, LLC and JERRY STOEV, ) ) Defendants-Appellees ) Honorable ) Brigid Mary McGrath, (Flash Acquisitions, LLC, Cross-Appellant). ) Judge, presiding.

JUSTICE HOFFMAN delivered the judgment of the court. Justices Cunningham and Rochford concurred in the judgment.

ORDER

¶1 Held: We vacated the circuit court’s grant of summary judgment in favor of the individual defendant and against the plaintiff, and we reversed the court’s grant of summary judgment in favor of the plaintiff and against the corporate defendant and we vacated the award of attorney fees in favor of the plaintiff. We remanded the matter for further proceedings No. 1-19-0325

¶2 The plaintiff, Debra Washington, appeals from an order of the circuit court of Cook

County, denying her motion for summary judgment against Jerry Stoev. She contends that the

circuit court erred when it denied her motion for summary judgment. Flash Acquisition, LLC

(Flash) cross-appeals, arguing that the circuit court erred when it granted summary judgment in

favor of the plaintiff and when it denied its motion to reconsider based on newly discovered

evidence. For the reasons that follow, we vacate the circuit court’s grant of summary judgment in

favor of Stoev and against the plaintiff, and we reverse the grant of summary judgment in favor of

the plaintiff and against Flash and vacate the award of attorney fees in favor of the plaintiff and

remand the matter for further proceedings.

¶3 The following facts relevant to the disposition of this appeal and cross-appeal were derived

from the pleadings and exhibits of record.

¶4 The plaintiff became a tenant of the property located at 7926 South Laflin Street (the

property) in September 2013. At the time, the property was owned by Everett Burnett. In February

2015, the plaintiff signed a one-year lease agreement with Burnett that was governed by the federal

section 8 Housing Choice Voucher (HCV) program administered by the Chicago Housing

Authority (CHA). The plaintiff’s rent was $1200 per month. At the expiration of the one-year

rental agreement, the plaintiff continued to rent the property from Burnett but there was no written

rental agreement.

¶5 Unbeknownst to the plaintiff, the property became the subject of foreclosure proceedings.

On May 13, 2016, Flash obtained the property pursuant to a judicial sale. After purchasing the

property, Flash learned from Burnett that the plaintiff was residing at the property as a tenant. On

July 31, 2016, Stoev, Flash’s managing member and sole employee, met with the plaintiff and

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presented her with a one-year lease agreement with a monthly rent of $1200. When the plaintiff

told Stoev that she could not accept the lease “at that point,” he presented her with a 90-day

termination of tenancy notice, which stated that Flash intended to file a forcible entry and detainer

action against her and a demand for possession.

¶6 On November 16, 2016, Flash filed an action for forcible entry and detainer against the

plaintiff (case no. 16 M1 719692). That action was ultimately dismissed with prejudice on

December 14, 2016. The following day, the plaintiff vacated the premises and tendered the keys

to Flash. Flash did not provide the plaintiff any financial support for relocation assistance after she

moved out.

¶7 On April 28, 2017, the plaintiff filed a two-count complaint against Flash, alleging that it

committed two violations of the City of Chicago’s Protecting Tenants in Foreclosed Rental

Property Ordinance (the ordinance). In count I, the plaintiff alleged that Flash violated section 5-

14-050 of the ordinance (Chicago Municipal Code § 5-14-050 (amended Apr. 15, 2015)), which

requires the new owner of a foreclosed rental property to pay a “qualified tenant” $10,600 in

relocation assistance when the owner elects not to renew or extend the tenant’s rental agreement.

In count II, the plaintiff alleged that Flash also violated section 5-14-050 of the ordinance by failing

to inform her via letter within 63 days of acquiring ownership of the property whether it had elected

to either renew her rental agreement or provide her with relocation assistance.

¶8 On November 16, 2017, Flash filed a motion to strike the plaintiff’s prayer for relief

pursuant to section 2-615 of the Code of Civil Procedure (735 ILCS 5/2-615 (West 2016)), arguing

that the plaintiff’s two claims should be merged into one because the ordinance does not allow her

to “stack” her damages and recover for each violation. On March 8, 2017, the circuit court entered

-3- No. 1-19-0325

an order granting Flash’s motion and allowing the plaintiff to amend her complaint to reflect that

Count II is pled in the alternative.

¶9 On April 30, 2018, and May 16, 2018, the plaintiff took the discovery deposition of Stoev

as Flash’s corporate representative. Also on May 16, 2018, the plaintiff filed her first amended

complaint, which added Stoev as a defendant. The amended complaint alleged the same two counts

as the initial complaint, however, the plaintiff now pled count II in the alternative.

¶ 10 The defendants filed their joint answer on June 25, 2018, denying that they failed in their

obligations under the ordinance. The defendants raised as an affirmative defense that the plaintiff

was offered a valid lease on July 31, 2016, which she rejected. Stoev also raised as an affirmative

defense that he did not qualify as an “owner” under the ordinance and, therefore, could not be held

personally liable.

¶ 11 On June 28, 2018, the plaintiff filed a motion for summary judgment against the defendants

on both counts of her amended complaint. The plaintiff argued that (1) she met the ordinance’s

definition of a qualified tenant because she lived at the property pursuant to a bona fide rental

agreement with Burnett; (2) the defendants are both “owners” under the ordinance; (3) the

defendants failed to provide her with the required notice advising her of their election to either

continue with her tenancy or provide her with relocation assistance within 63 days; and (4) the

defendants failed to pay her the statutorily required relocation assistance. In support of her motion,

the plaintiff attached, inter alia, portions of Stoev’s discovery deposition testimony and the

defendants’ joint answer to her complaint.

¶ 12 The defendants filed a joint response in opposition to the plaintiff’s motion for summary

judgment on July 31, 2018. In their response, the defendants argued that (1) the plaintiff was not

-4- No. 1-19-0325

a qualified tenant under the ordinance because her $1200 rent was substantially below market

value; (2) she was not entitled to relocation assistance because she rejected Flash’s July 31, 2016

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2021 IL App (1st) 190325-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/washington-v-flash-aquisitions-llc-illappct-2021.