Lockwood v. Professional Neurological Services, Ltd.

Defendants, a group of doctors, appealed from a series of orders entered against them and in favor of the plaintiff, their former employee. The former employee had prevailed in an employment discrimination claim brought before the Chicago Commission on Human Relations that was brought by the doctors’ practice group. The defendants sought administrative review, and the circuit court affirmed. In supplementary proceedings to enforce the judgment, the circuit court allowed plaintiff to pierce the corporate veil and to hold the doctors personally liable for plaintiff’s judgment against their practice group. On appeal, the defendant doctors argued that the circuit court erred by permitting plaintiff to bring an action to pierce the corporate veil in supplementary proceedings, that the trial court erred in awarding attorneys fees incurred after entry of judgment, and that the circuit court did not have jurisdiction where plaintiff improperly served a petition to revive her judgment. The appellate court vacated the judgment and remanded, explaining that longstanding precedent prohibits a judgment debtor from bringing an action to pierce the corporate veil within supplementary proceedings. However, the appellate court further held that the plaintiff was allowed to recover her attorneys fees and that any defect in service did not deprive the circuit court of jurisdiction. (ODEN JOHNSON and NAVARRO, concurring)