527 S. Clinton, LLC v. Westloop Equities, LLC

Illinois Appellate Court
Civil Court
Easements
Citation
Case Number: 
2014 IL App (1st) 131401
Decision Date: 
Monday, March 10, 2014
District: 
1st Dist.
Division/County: 
Cook Co.,1st Div.
Holding: 
Affirmed in part and reversed in part.
Justice: 
HOFFMAN
Plaintiff sought judicial declarations that its proposed development of multi-story commercial and residential building would not violate easement held by Defendant. Easement provided that it would remain in force so long as property is continously operated as a hotel. Hotel closed for a decade due to bankruptcy, but then Defendant purchased it, refurbished and reopened the hotel. Language of agreement provided for termination upon non-temporary business interruption, and thus no action by any party was required to effectuate termination of easement. Hotel closure for 10 years was not a "temporary interruption", and automatic stay provision of Bankruptcy Code did not apply. Evidence presented factual issues whether development plan was a substantial change, and thus summary judgment should not have been granted. (CONNORS and CUNNINGHAM, concurring.)