{ "id": 4302549, "name": "BRUCE HIGGINS, Plaintiff-Appellant and Cross-Appellee, v. DAVID G. RICHARDS, Defendant-Appellee and Cross-Appellant", "name_abbreviation": "Higgins v. Richards", "decision_date": "2010-06-17", "docket_number": "No. 5\u201408\u20140605", "first_page": "1120", "last_page": "1127", "citations": [ { "type": "official", "cite": "401 Ill. App. 3d 1120" } ], "court": { "name_abbreviation": "Ill. App. Ct.", "id": 8837, "name": "Illinois Appellate Court" }, "jurisdiction": { "id": 29, "name_long": "Illinois", "name": "Ill." }, "cites_to": [ { "cite": "373 Ill. App. 3d 738", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 4269572 ], "weight": 2, "year": 2007, "pin_cites": [ { "page": "740" }, { "page": "739" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/373/0738-01" ] }, { "cite": "367 Ill. App. 3d 1026", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 4266376 ], "year": 2006, "pin_cites": [ { "page": "1029" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/367/1026-01" ] }, { "cite": "361 Ill. 551", "category": "reporters:state", "reporter": "Ill.", "case_ids": [ 2595803 ], "year": 1935, "opinion_index": 0, "case_paths": [ "/ill/361/0551-01" ] }, { "cite": "31 Ill. App. 3d 343", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 2709866 ], "year": 1975, "pin_cites": [ { "page": "347" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/31/0343-01" ] }, { "cite": "214 Ill. 2d 187", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 8450836 ], "year": 2005, "pin_cites": [ { "page": "204" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/214/0187-01" ] }, { "cite": "348 Ill. App. 3d 445", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 4021876 ], "year": 2004, "pin_cites": [ { "page": "450", "parenthetical": "noting that \"by its own terms, Supreme Court Rule 191(a) is applicable only to affidavits under sections 2 - 1005, 2 - 619, and 2 - 301(b) of the Code of Civil Procedure [citation] *** and does not apply to affidavits filed in conjunction with any other type of civil proceedings\"" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/348/0445-01" ] }, { "cite": "265 Ill. App. 3d 376", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 872487 ], "year": 1994, "pin_cites": [ { "page": "379" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/265/0376-01" ] }, { "cite": "232 Ill. 2d 546", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3619419 ], "year": 2009, "pin_cites": [ { "page": "558-59" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/232/0546-01" ] }, { "cite": "202 Ill. 2d 499", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 1442034 ], "year": 2002, "pin_cites": [ { "page": "505" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/202/0499-01" ] }, { "cite": "224 Ill. 2d 312", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3606828 ], "year": 2007, "pin_cites": [ { "page": "323" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/224/0312-01" ] }, { "cite": "215 Ill. 2d 416", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 4059900 ], "year": 2005, "pin_cites": [ { "page": "423" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/215/0416-01" ] }, { "cite": "366 Ill. App. 3d 135", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 4264611 ], "year": 2006, "pin_cites": [ { "page": "141" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/366/0135-01" ] }, { "cite": "325 Ill. App. 3d 49", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 570864 ], "year": 2001, "pin_cites": [ { "page": "53-54" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/325/0049-01" ] }, { "cite": "367 Ill. App. 3d 559", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 4265503 ], "weight": 2, "year": 2006, "pin_cites": [ { "page": "562" }, { "page": "561" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/367/0559-01" ] }, { "cite": "375 Ill. App. 3d 26", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 4271540 ], "year": 2007, "pin_cites": [ { "page": "30" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/375/0026-01" ] }, { "cite": "326 U.S. 310", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6157001 ], "weight": 3, "year": 1945, "pin_cites": [ { "page": "319" }, { "page": "104" }, { "page": "160" } ], "opinion_index": 0, "case_paths": [ "/us/326/0310-01" ] }, { "cite": "471 U.S. 462", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6205101 ], "weight": 3, "year": 1985, "pin_cites": [ { "page": "471-72" }, { "page": "540" }, { "page": "2181" } ], "opinion_index": 0, "case_paths": [ "/us/471/0462-01" ] }, { "cite": "102 Ill. 2d 342", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3156797 ], "year": 1984, "pin_cites": [ { "page": "348" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/102/0342-01" ] }, { "cite": "348 Ill. App. 3d 26", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 4022806 ], "year": 2004, "pin_cites": [ { "page": "34" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/348/0026-01" ] } ], "analysis": { "cardinality": 769, "char_count": 17359, "ocr_confidence": 0.77, "pagerank": { "raw": 4.03580807328026e-08, "percentile": 0.14482388741583002 }, "sha256": "5f91466085f7ccea3526b2a3f22c2810ea7289220a5482946b77a43ef9d4199a", "simhash": "1:eaaa1df640c94556", "word_count": 2866 }, "last_updated": "2023-07-14T16:03:46.574655+00:00", "provenance": { "date_added": "2019-08-29", "source": "Harvard", "batch": "2018" }, "casebody": { "judges": [], "parties": [ "BRUCE HIGGINS, Plaintiff-Appellant and Cross-Appellee, v. DAVID G. RICHARDS, Defendant-Appellee and Cross-Appellant." ], "opinions": [ { "text": "JUSTICE WEXSTTEN\ndelivered the opinion of the court:\nIn the circuit court of Madison County, the plaintiff, Bruce Higgins, successfully sued the defendant, David G. Richards, in a negligence action stemming from an automobile accident that occurred in St. Louis County, Missouri. On appeal, the plaintiff contends that he is entitled to a new trial on the issue of damages. The defendant cross-appeals arguing that the judgment entered against him is void for a lack of personal jurisdiction. For the reasons that follow, we agree with the defendant.\nBACKGROUND\nIn September 1998, the defendant, a resident of Ellisville, Missouri, and an employee of West County Motor Company (West County) in Manchester, Missouri, took the plaintiff, a resident of Madison County, for a test drive in one of West County\u2019s BMW automobiles. While demonstrating the BMW\u2019s capabilities, the defendant attempted to negotiate a turn at a high rate of speed, lost control of the vehicle, and crashed into an embankment behind a department store in Manchester. The plaintiff suffered resulting injuries, and in September 2000, he brought suit against West County and the defendant in the circuit court of Madison County. The record indicates that on October 9, 2000, West County and the defendant were both served with a summons in Missouri.\nIn January 2001, West County filed a motion to dismiss for a lack of personal jurisdiction pursuant to section 2 \u2014 301 of the Code of Civil Procedure (the Code) (735 ILCS 5/2 \u2014 301 (West 2000)). The motion alleged, inter alia, that the circuit court did not have personal jurisdiction over West County because West County\u2019s contacts with Illinois were insufficient to justify that jurisdiction and because the plaintiff\u2019s complaint failed to \u201callege any connection between the cause of action and the forum in which the matter [was] brought.\u201d In a memorandum subsequently filed in support of its motion to dismiss, West County specifically maintained that none of the factors enumerated in the Illinois long-arm statute (735 ILCS 5/2 \u2014 209 (West 2000)) supported a finding of personal jurisdiction. In April 2001, the circuit court entered an order granting West County\u2019s motion to dismiss.\nIn January 2004, finding that the defendant had been served with summons but had \u201cfailed to appear or otherwise plead in [the] cause,\u201d the circuit court entered a default judgment against him. In response, the defendant promptly filed, in a single document, a motion to set aside the default judgment pursuant to section 2 \u2014 1301(e) of the Code (735 ILCS 5/2 \u2014 1301(e) (West 2004)) and a motion to dismiss for a lack of personal jurisdiction pursuant to section 2 \u2014 301. As West County had previously done, the defendant referenced the Illinois long-arm statute in support of his argument that the circuit court should dismiss the cause against him for a lack of personal jurisdiction. In May 2004, the circuit court entered an order granting the defendant\u2019s motion to set aside the default judgment but denying his motion to dismiss for a lack of personal jurisdiction. Thereafter, in his answer to the plaintiff\u2019s complaint, the defendant asserted a lack of personal jurisdiction as an affirmative defense. In July 2004, the circuit court entered a summary judgment on the issue of the defendant\u2019s liability and set the cause for a trial on damages only.\nIn June 2007, following numerous continuances and case management conferences, the defendant filed a motion to reconsider the denial of his motion to dismiss for a lack of personal jurisdiction. The defendant\u2019s motion to reconsider alleged that he had committed no acts submitting him to the jurisdiction of the circuit court under the Illinois long-arm statute and that the plaintiff had failed to allege any basis that would provide the circuit court with jurisdiction over his person. The motion further noted that in April 2001, the circuit court had granted West County\u2019s motion to dismiss for a lack of personal jurisdiction on the same grounds.\nIn August 2007, following a hearing on the matter, the circuit court entered an order denying the defendant\u2019s motion to reconsider the denial of his motion to dismiss for a lack of personal jurisdiction. Adopting the plaintiff\u2019s argument, the court noted that because the defendant\u2019s combined motion to set aside the default judgment and dismiss for a lack of personal jurisdiction was not filed in parts with each part specifying the statutory section under which each request for relief was being brought, the motion failed to comply with section 2 \u2014 619.1 of the Code (735 ILCS 5/2 \u2014 619.1 (West 2004)) and thus failed to comply with the requirements of section 2 \u2014 301(a) of the Code (735 ILCS 5/2 \u2014 301(a) (West 2004)). Quoting section 2 \u2014 301 (a \u2014 5) of the Code (735 ILCS 5/2 \u2014 301(a\u20145) (West 2004)), the court then held, \u201cFailure to follow the strictures of 2 \u2014 301(a) \u2018waives all objections to the court\u2019s jurisdiction over the party\u2019s person.\u2019 \u201d\nPursuant to Supreme Court Rule 306(a)(3) (210 Ill. 2d R. 306(a)(3)), the defendant subsequently filed a petition for leave to appeal, which this court denied as untimely. Following this court\u2019s denial of the defendant\u2019s petition for rehearing, the defendant filed a petition for leave to appeal in the supreme court, which was also denied.\nIn January 2008, the cause proceeded to a jury trial on the issue of damages, and on the jury\u2019s verdict, the circuit court entered a judgment in favor of the plaintiff and against the defendant in the amount of $28,784. The present appeals followed.\nDISCUSSION\nOn appeal, the plaintiff contends that he is entitled to a new trial on the issue of damages, and the defendant cross-appeals, arguing, inter alia, that the judgment entered against him is void for a lack of personal jurisdiction. We agree that the judgment entered against the defendant is void, and we accordingly vacate it.\n\u201cThe United States Supreme Court has determined that a state\u2019s power to invoke personal jurisdiction over a nonresident defendant is limited by the due process clause of the fourteenth amendment (U.S. Const., amend. XIV).\u201d Riemer v. KSL Recreation Corp., 348 Ill. App. 3d 26, 34 (2004), citing Maunder v. DeHavilland Aircraft of Canada, Ltd., 102 Ill. 2d 342, 348 (1984). \u201cThe Due Process Clause protects an individual\u2019s liberty interest in not being subject to the binding judgments of a forum with which he has established no meaningful \u2018contacts, ties, or relations.\u2019 \u201d Burger King Corp. v. Rudzewicz, 471 U.S. 462, 471-72, 85 L. Ed. 2d 528, 540, 105 S. Ct. 2174, 2181 (1985), quoting International Shoe Co. v. Washington, 326 U.S. 310, 319, 90 L. Ed. 95, 104, 66 S. Ct. 154, 160 (1945). \u201cThe due process clause [thus] limits a state\u2019s exercise of personal jurisdiction over a nonresident defendant to those instances where the defendant had at least \u2018minimum contacts\u2019 with the state.\u201d Commercial Coin Laundry Systems v. Loon Investments, LLC, 375 Ill. App. 3d 26, 30 (2007). The minimum-contacts standard ensures \u201cthat a nonresident will not be haled into a forum solely as a result of random, fortuitous, or attenuated contacts with the forum or the unilateral acts of a consumer or some other third person.\u201d Roiser v. Cascade Mountain, Inc., 367 Ill. App. 3d 559, 562 (2006). \u201cWhen determining whether jurisdiction is proper over a nonresident defendant, courts evaluate whether jurisdiction is proper under the long-arm statute and whether jurisdiction would comport with constitutional standards of due process\u201d (Khan v. Van Remmen, Inc., 325 Ill. App. 3d 49, 53-54 (2001)), and \u201cwhere the contacts between an out-of-state defendant and [an] Illinois plaintiff satisfy both federal and state due process concerns, the requirements of the long-arm statute have been met\u201d (Commerce Trust Co. v. Air 1st Aviation Cos., 366 Ill. App. 3d 135, 141 (2006)). In any event, \u201c[t]he plaintiff bears the burden of establishing a prima facie basis upon which jurisdiction over an out-of-state resident may be exercised.\u201d Roiser, 367 Ill. App. 3d at 561.\nInitially, we note that the plaintiff has never attempted to establish a prima facie basis upon which personal jurisdiction over the defendant could be exercised in the present case, nor has he ever contested the merits of the defendant\u2019s contentions regarding the circuit court\u2019s lack of personal jurisdiction. Given that the only connection between the plaintiffs suit and the circuit court of Madison County is that the plaintiff is a resident of Madison County, this is understandable. Instead, the plaintiff has consistently maintained, as he does on appeal, that by failing to strictly comply with section 2 \u2014 301, the defendant waived all objections to the circuit court\u2019s lack of jurisdiction. Because the issue before us is purely a matter of statutory construction, our review is de novo. People ex rel. Director of Corrections v. Booth, 215 Ill. 2d 416, 423 (2005).\nWhen a court construes a statute, the \u201cprimary objective is to ascertain and give effect to legislative intent, the surest and most reliable indicator of which is the statutory language itself.\u201d People v. Perry, 224 Ill. 2d 312, 323 (2007). \u201cIn addition, where a statute is clear and unambiguous, courts cannot read into the statute limitations, exceptions, or other conditions not expressed by the legislature,\u201d and courts \u201cshould evaluate a statutory provision as a whole rather than reading phrases in isolation.\u201d People v. Glisson, 202 Ill. 2d 499, 505 (2002). \u201c[C]ourts are [also] obliged to construe statutes to avoid absurd, unreasonable, or unjust results ***.\u201d Roselle Police Pension Board v. Village of Roselle, 232 Ill. 2d 546, 558-59 (2009).\nIn pertinent part, section 2 \u2014 301 states as follows:\n\u201c(a) Prior to the filing of any other pleading or motion other than a motion for an extension of time to answer or otherwise appear, a party may object to the court\u2019s jurisdiction over the party\u2019s person *** by filing a motion to dismiss the entire proceeding or any cause of action involved in the proceeding or by filing a motion to quash service of process. Such a motion may be made singly or included with others in a combined motion, but the parts of a combined motion must be identified in the manner described in Section 2 \u2014 619.1. ***\n(a \u2014 5) If the objecting party files a responsive pleading or a motion (other than a motion for an extension of time to answer or otherwise appear) prior to the filing of a motion in compliance with subsection (a), that party waives all objections to the court\u2019s jurisdiction over the party\u2019s person.\u201d 735 ILCS 5/2 \u2014 301(a), (a \u2014 5) (West 2004).\nSection 2 \u2014 619.1 provides as follows:\n\u201cMotions with respect to pleadings under Section 2 \u2014 615, motions for involuntary dismissal or other relief under Section 2 \u2014 619, and motions for summary judgment under Section 2 \u2014 1005 may be filed together as a single motion in any combination. A combined motion, however, shall be in parts. Each part shall be limited to and shall specify that it is made under one of Sections 2 \u2014 615, 2 \u2014 619, or 2 \u2014 1005. Each part shall also clearly show the points or grounds relied upon under the Section upon which it is based.\u201d 735 ILCS 5/2 \u2014 619.1 (West 2004).\nOstensibly, section 2 \u2014 619.1 was the legislature\u2019s response to the fact that \u201c[rjeviewing courts have long disapproved of [the] slipshod practice\u201d of filing hybrid motions to dismiss pursuant to both sections 2 \u2014 615 and 2 \u2014 619, because those motions \u201ccause[ ] unnecessary complication and confusion.\u201d Talbert v. Home Savings of America, F.A., 265 Ill. App. 3d 376, 379 (1994).\nWhen denying the defendant\u2019s motion to reconsider the denial of his motion to dismiss for a lack of personal jurisdiction, the circuit court determined that the defendant\u2019s combined motion to set aside the default judgment and dismiss for a lack of personal jurisdiction failed to comply with section 2 \u2014 619.1 because the motion was not filed in parts with each part specifying the statutory section under which each request for relief was being brought. The court thus determined that the combined motion was not filed in compliance with section 2 \u2014 301(a) and that, pursuant to section 2 \u2014 301(a\u20145), the defendant had therefore waived his objections to the court\u2019s lack of personal jurisdiction. By its own terms, however, section 2 \u2014 619.1 is applicable only to motions combining motions filed pursuant to any two of its three listed sections, i.e., sections 2 \u2014 615, 2 \u2014 619, and 2 \u2014 1005 of the Code (735 ILCS 5/2 \u2014 615, 2 \u2014 619, 2 \u2014 1005 (West 2004)). Cf. Botello v. Illinois Central R.R. Co., 348 Ill. App. 3d 445, 450 (2004) (noting that \u201cby its own terms, Supreme Court Rule 191(a) is applicable only to affidavits under sections 2 \u2014 1005, 2 \u2014 619, and 2 \u2014 301(b) of the Code of Civil Procedure [citation] *** and does not apply to affidavits filed in conjunction with any other type of civil proceedings\u201d). We thus interpret section 2 \u2014 301(a)\u2019s use of the term \u201ccombined motion\u201d as referring only to a motion combining motions filed pursuant to any two of the three sections referenced in section 2 \u2014 619.1. Section 2 \u2014 301(a) specifically refers to the \u201cmanner described in Section 2 \u2014 619.1,\u201d section 2 \u2014 619.1 specifically refers to sections 2 \u2014 615, 2 \u2014 619, and 2 \u2014 1005, and \u201c[w]hen a statute makes specific references, it is to be inferred that all omissions are understood as exclusions.\u201d People v. Jones, 214 Ill. 2d 187, 204 (2005).\nHere, the defendant\u2019s section 2 \u2014 301 motion to dismiss for a lack of personal jurisdiction was combined with his motion to set aside the default judgment pursuant to section 2 \u2014 1301(e), but it was not combined with a motion combining motions filed pursuant to any two of the three sections referenced in section 2 \u2014 619.1. Section 2 \u2014 619.1 was thus inapplicable to the defendant\u2019s motion, and he need not have complied with its directives. Moreover, even assuming otherwise, we would nevertheless conclude that the circuit court erred in its application of section 2 \u2014 301.\nPursuant to section 2 \u2014 301 (a \u2014 5), by filing a responsive pleading or motion \u201cprior to the filing of a motion in compliance with subsection (a),\u201d a party waives all objections regarding the circuit court\u2019s lack of personal jurisdiction. 735 ILCS 5/2 \u2014 301(a\u20145) (West 2004). We read section 2 \u2014 301(a\u20145) as codifying the long-standing rule that \u201ca party may waive a defect in jurisdiction over the person by proceeding without objection.\u201d Mullaney, Wells & Co. v. Savage, 31 Ill. App. 3d 343, 347 (1975), citing People v. Securities Discount Corp., 361 Ill. 551 (1935). Thus, we believe that section 2 \u2014 301(a\u20145)\u2019s language \u2014 \u201cin compliance with subsection (a)\u201d \u2014 refers to the time that a motion to dismiss for a lack of personal jurisdiction must be filed and is not meant to impose a strict mandate regarding section 2 \u2014 619.l\u2019s pleading requirements. Section 2 \u2014 619.1 is not a strict mandate (see Burton v. Airborne Express, Inc., 367 Ill. App. 3d 1026, 1029 (2006)), and even if it were, we could not conclude that a party\u2019s failure to comply with its requirements would be sufficient to waive the party\u2019s otherwise timely objection to a court\u2019s lack of personal jurisdiction. We agree with the defendant\u2019s suggestion that interpreting section 2 \u2014 301(a\u20145) in that manner would allow a technical pleading requirement to \u201cobliterate due process concerns.\u201d\nHere, the defendant repeatedly objected to the circuit court\u2019s jurisdiction over his person, and the plaintiff was in no way prejudiced by the defendant\u2019s failure to separate his combined motion into specific parts. The defendant\u2019s motion to dismiss specifically stated that it was being brought pursuant to section 2 \u2014 301, and his motion to set aside the default judgment specifically stated that it was being brought pursuant to section 2 \u2014 1301(e). The circuit court properly granted West County\u2019s motion to dismiss for a lack of personal jurisdiction but basically denied the defendant\u2019s request for the same relief because his motion lacked headings. Under the circumstances, the court\u2019s denial of the defendant\u2019s motion to reconsider the denial of his motion to dismiss for a lack of personal jurisdiction was unjust and unreasonable, and even assuming that the defendant had been required to comply with section 2 \u2014 619.1\u2019s pleading requirements, we could not support a reading of section 2 \u2014 301 that would lend itself to that result.\n\u201cWhere a trial court does not have personal jurisdiction over a party, any order or judgment entered against that party is void and subject to direct or collateral attack at any time.\u201d Howard v. Missouri Bone & Joint Center, Inc., 373 Ill. App. 3d 738, 740 (2007). Here, the circuit court lacked jurisdiction over the defendant, and we accordingly vacate the judgment entered against him. See Howard, 373 Ill. App. 3d at 739.\nVacated.\nWELCH and SPOMER, JJ., concur.", "type": "majority", "author": "JUSTICE WEXSTTEN" } ], "attorneys": [ "Bob L. Perica, of Perica Law Firm, of Wood River, for appellant.", "Karen L. Kendall, of Heyl, Royster, Voelker & Allen, of Peoria, and Laura L. Althardt and Michael D. Clark, both of Heyl, Royster, Voelker & Allen, of Edwardsville, for appellee." ], "corrections": "", "head_matter": "BRUCE HIGGINS, Plaintiff-Appellant and Cross-Appellee, v. DAVID G. RICHARDS, Defendant-Appellee and Cross-Appellant.\nFifth District\nNo. 5\u201408\u20140605\nOpinion filed June 17, 2010.\nRehearing denied July 14, 2010.\nBob L. Perica, of Perica Law Firm, of Wood River, for appellant.\nKaren L. Kendall, of Heyl, Royster, Voelker & Allen, of Peoria, and Laura L. Althardt and Michael D. Clark, both of Heyl, Royster, Voelker & Allen, of Edwardsville, for appellee." }, "file_name": "1120-01", "first_page_order": 1136, "last_page_order": 1143 }