1541 North Bosworth Condominium Ass’n v. Hanna Architects

Illinois Appellate Court
Civil Court
Ordinances
Citation
Case Number: 
2021 IL App (1st) 200594
Decision Date: 
Wednesday, December 29, 2021
District: 
1st Dist.
Division/County: 
Cook Co., 3d Div.
Holding: 
Reversed.
Justice: 
ELLIS

Defendant architects designed and self-certified plans for construction of a 3-unit residential condominium in Chicago, and the builder obtained a permit through City's Self-Certification Permit Program (SCPP). FIve years after construction was completed, a windstorm exposed the design defect that the building lacked a lateral structural support system to withstand wind loads as required by city building code. Plaintiff (condominium association) is not a member of the class for whose benefit the ordinance was enacted. Neither the city ordinance nor the SCPP program itself implies a cause of action against Defendant architects. As circuit court's sole basis for granting judgment for Plaintiff was its finding that an implied cause of action existed, judgment for Plaintiff is reversed.  (McBRIDE and BURKE, concurring.)