Reyes v. Menard, Inc.

Illinois Appellate Court
Criminal Court
Citation
Case Number: 
2012 IL App (1st) 112555
Decision Date: 
November 21, 2012
District: 
1st Dist.
Division/County: 
Cook Co.,6th Div.
Justice: 
R. GORDON
Holding: 
Reversed.
Court erred in sanctioning Plaintiff in arbitration case via self-executing order barring her from testifying or presenting evidence at arbitration hearing, where Plaintiff's sole discovery violation was being one week late in providing discovery answers, without first obtaining leave of court. Rule 219(c) does not provide trial court with statutory authority to bar a party from presenting testimony other than the plaintiff's. When Plaintiff was later barred from rejecting arbitration award, the Rule 219(c) order was tantamount to a dismissal of plaintiff's case. (LAMPKIN, concurring; GARCIA, specially concurring.)