CLP Venture, LLC v. Central States

Illinois Appellate Court
Civil Court
Enforcement of Judgment
Citation
Case Number: 
2023 IL App (1st) 230574
Decision Date: 
Wednesday, November 22, 2023
District: 
1st Dist.
Division/County: 
5th Div./Cook Co.
Holding: 
Reversed and remanded.
Justice: 
MIKVA

Plaintiff brought an action for quiet title after the defendant sought to revive judgments it had received against the plaintiff more than seven years prior by recording the revived judgments as a lien against plaintiff’s property. The trial court ruled in favor of the plaintiff and voided defendant’s liens and defendant appeal. The appellate court reversed and remanded, finding that section 12-101 of the Code of Civil Procedure allows a judgment creditor to record a revived judgment as a new lien on a debtor’s property after the expiration of seven years. (MITCHELL and NAVARRO, concurring)