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2314 Lincoln Park West Condominium Association v. Mann, Gin, Ebel & Frazer, Limited

Illinois Supreme Court
555 N.E.2d 346 (1990)


Facts

The owners of 39 condominiums in a Chicago condominium complex were dissatisfied with the quality of the doors and windows, heating-and-cooling systems, utilities, and garages of their units. The owners’ association, the 2314 Lincoln Park West Condominium Association (Lincoln) (plaintiff), sued the architectural firm that had designed the complex—Mann, Gin, Ebel & Frazier, Ltd. (Mann) (defendant). Lincoln alleged that Mann had negligently designed the project and sought damages for the cost of repairs. The trial court submitted a certified question to the Illinois Supreme Court to determine whether Illinois law permitted recovery against architectural firms in tort for purely economic losses.

Rule of Law

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Issue

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Holding and Reasoning (Miller, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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