Illinois Appellate Court
Civil Court
Proximate Cause
Fire severely damaged Plaintiff's casino during casino renovations. Plaintiff and several companies that issued insurance policies to Plaintiff filed suit alleging that Defendant's failure to properly clean the ducts in the casino's kitchen caused the fire. Court properly granted summary judgment for Defendant, as it had not breached any duty to Plaintiff. Evidence showed that Defendant attempted to schedule cleanings that Plaintiff declined. Defendant's conduct was not the legal cause of the fire but merely created a serious condition to exist. Court properly found that Plaintiff is unable to establish proximate cause as a matter of law. (LAMPKIN and REYES, concurring.)