City of Chicago Heights v. Crotty

Donald Crotty and Donald Schak (collectively, the owners) owned apartment buildings. The owners filed a federal civil-rights action against the City of Chicago Heights (the city), alleging that the city had demolished the owners’ buildings in violation of their civil rights. The parties entered into a settlement agreement that required the city to compensate the owners in exchange for a release of the owners’ federal-action claims. The agreement also provided that it was the intention of the owners to transfer the buildings to the city for the sum of $1, and the city agreed to accept the buildings. In addition, the agreement contained the following phrases: “the Municipality shall pay” a sum of money, the payments “shall be made by wire transfer,” and the amounts “shall bear” a certain interest. Subsequently, the owners attempted to transfer buildings to a third party, and the city refused to issue the transfer stamps that the owners needed to transfer the buildings. The city (plaintiff) then filed in trial court a complaint for specific performance, requesting that the trial court order the owners (defendants) to transfer the buildings to the city pursuant to the settlement agreement. Both parties moved for summary judgment. The trial court denied the city’s motion and granted the owners’ motion. The city appealed.