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City of Chicago v. La Salle National Bank Trust No. 34471

Citations: 20 Ill. App. 3d 462; 314 N.E.2d 737; 1974 Ill. App. LEXIS 2461Docket: No. 55855

Court: Appellate Court of Illinois; June 10, 1974; Illinois; State Appellate Court

Narrative Opinion Summary

In this case, the City of Chicago filed a complaint against several parties, including La Salle National Bank and Henning Corporations, alleging violations of the Municipal Code during the conversion of a building from a hotel to apartments. The city sought fines and other remedies. Concurrently, the Federal Housing Authority initiated foreclosure proceedings, during which a receiver was appointed. The circuit court continued its action against the Henning Corporations, who eventually achieved compliance with the code. Despite this, the court imposed a fine of $400, which the appellants contested on several grounds. They argued constitutional violations and claimed lack of jurisdiction due to the foreclosure proceedings. The court dismissed these arguments, noting the violations occurred while the appellants had possession and ruled that the doctrine of double jeopardy did not apply, as the proceedings were quasi-criminal. The appellants' Fifth Amendment claim was not considered on appeal since it was not raised in the trial court. Ultimately, the trial court's judgment was affirmed, and the fine was upheld.

Legal Issues Addressed

Application of Double Jeopardy Doctrine

Application: The court ruled that double jeopardy does not apply in quasi-criminal proceedings for municipal code violations.

Reasoning: Lastly, the appellants claim former jeopardy applies since the fine was imposed after an earlier decree was vacated; however, the court found this doctrine inapplicable as the proceedings were quasi-criminal, and jeopardy applies strictly to criminal cases.

Jurisdiction and Foreclosure Proceedings

Application: The trial court maintained jurisdiction to impose a fine for code violations that occurred prior to and during the foreclosure proceedings.

Reasoning: They also contend that the trial court lacked jurisdiction to impose the fine due to the foreclosure decree. However, the violations occurred before the foreclosure and while they had possession, thus justifying the fine.

Municipal Code Violations and Remedies

Application: The city sought remedies including fines and injunctions for violations of the Municipal Code related to building conversions.

Reasoning: The complaint alleged that a six-story building at 869 West Buena, being converted from a hotel to apartments by the Henning Corporations, violated several provisions of the Municipal Code.

Waiver of Constitutional Claims on Appeal

Application: Constitutional claims not raised at trial cannot be considered on appeal.

Reasoning: The appellants argue that the fine violates the Fifth Amendment, but this issue was not raised in the trial court and is therefore not considered on appeal.