2026-09-10 · Illinois · Courts

What happened. On March 21, 2025 the Illinois Appellate Court, First District, Fifth Division, affirmed a finding of no breach in Blue Ocean 21-1, L.L.C. v. Greenway Court Condominium Ass'n, 2025 IL App (1st) 232423-U. It is a Rule 23 order and is not precedential.¹

The request was, in the court's words, “the proverbial 'laundry list' rather than one made with 'particularity' as the statute requires.”

The statutory framework

The court analysed the demand under 765 ILCS 605/19(a)(1)-(10), which enumerates the records an association must maintain and produce; 19(b), which requires a written request stating the records sought with particularity and a proper purpose; and 19(g), which sets out exemptions.

The derivative breach-of-fiduciary-duty count fell with the Section 19 count.

Two procedural facts that decided the appeal

The appellant filed a brief and no transcripts or bystander's report. Under settled Illinois law the appellate court cannot disturb a trial court's finding without a record of what happened below.

And the plaintiff was a former owner, still demanding records — as the court put it — “for years after the unit was disposed of by the member, possibly in a quest for statutory attorney fees.”

1. Blue Ocean 21-1, L.L.C. v. Greenway Court Condominium Ass'n, 2025 IL App (1st) 232423-U (Rule 23 order, March 21, 2025) ↩
2. 765 ILCS 605/19, Condominium Property Act, records and inspection ↩