Channon v. Westward Management

In a case involving the Condominium Property Act, the court considered whether section 22.1 of the Act provided an implied cause of action in favor of a condominium unit seller against a property manager, as agent of a condominium association or board of directors, based on allegations that the property manager charged excessive fees for the production of information required to be disclosed to a prospective buyer under the Act. The supreme court answered the question in the negative finding that section 22.1 did not create an implied private right of action by condominium unit sellers. (THEIS, ANNE M. BURKE, NEVILLE, OVERSTREET, and HOLDER WHITE, concurring and MICHAEL J. BURKE, specially concurring)