Ventus Holdings, LLC v. Raddle

Plaintiff filed an eviction action after the defendant tenant failed to vacate a property after the plaintiff did not renew his lease. Defendant filed a motion for summary judgment arguing that the property was subject to state regulations under the Illinois rental housing support program and that the program’s regulations prevented plaintiff from refusing the renew the lease unless it had good cause and that plaintiff failed to show good cause. The trial court denied the motion, the case proceeded to trial, the trial court entered an eviction order, and defendant appealed. The appellate court affirmed both the denial of summary judgment and entry of the eviction order, finding that landlords in the RHS program are only required to show good cause when evicting a tenant and not when making a renewal decision and the good cause requirement was met where defendant refused to leave the property after being timely notified of the expiration of his lease. (HOFFMAN and OCASIO, concurring)