People ex rel. Madigan v. Wildermuth

Illinois Supreme Court
Civil Court
Case Number: 
2017 IL 120763
Decision Date: 
September 21, 2017
1st Dist.
Cook Co.
Appellate court affirmed in part and vacated in part; remanded.

State may claim a violation under Illinois Human Rights Act pursuant to a reverse redlining theory where it did not allege that the defendant acted as a mortgage lender. Court erred in dismissing complaint with prejudice; dismissal should have been without prejudice, as grounds relied upon as to "other financial assistance" were lacking. Defendant's conduct, in filling out paperwork for loan modification process and recommending short sales did not amount to "financial assistance". Defendants were not a necessary and direct channel through which funds flow. (KARMEIER, FREEMAN, KILBRIDE, GARMAN, BURKE, and THEIS, concurring.)