Poris v. Lake Holiday Property Owners Association

Illinois Supreme Court
Civil Court
Case Number: 
2013 IL 113907
Decision Date: 
January 25, 2013
3d Dist.
LaSalle Co.
Appellate court reversed in part and affirmed in part; circuit court affirmed.
Plaintiff was ticketed, by lake association security officer, for speeding while driving on a road on private lake community grounds. Association was within its authority in establishing and enforcing speed limits on Association property, and security officers were not attempting to unlawfully assert police powers in issuing traffic citations. Officer had probable cause to believe that offense was committed, in clocking Plaintiff's speed at 34 mph in 25 mph private road; and probable cause is absolute bar to claim for false imprisonment. (KILBRIDE, FREEMAN, GARMAN, KARMEIER, BURKE, and THEIS, concurring.)