Wednesday, December 25, 2013

Board of Education of Community School District No. 220 v. Village of Hoffman Estates case brief

Board of Education of Community School District No. 220 v. Village of Hoffman Estates case brief summary
467 N.E.2d 1064 (1984)

CASE SYNOPSIS
Defendant village sought review of the judgment of the Circuit Court of Cook County (Illinois), which granted summary judgment in favor of plaintiff school district in an action seeking a declaration of plaintiff's rights as a beneficiary under the terms of certain annexation agreements.

CASE FACTS
Plaintiff school district brought a declaratory action that sought a declaration that it was entitled to received certain escrowed funds pursuant to annexation agreements to which defendant village was a party, and that the contracting parties did not have the power to alter the terms of such agreements without plaintiff's consent, as a donee beneficiary. The trial court granted summary judgment in favor of plaintiff, and defendant sought review.

DISCUSSION

  • On appeal, the court held that, based on the plain language of the contract, plaintiff was merely a potential beneficiary of the promise to pay certain specified sums for the benefit of education. 
  • The court held that the actual beneficiary of the promise had not yet been identified at the time defendant and property owners had modified the annexation agreement. 
  • The court ruled that until a beneficiary was vested, the parties were free to modify their agreement.

CONCLUSION
The court reversed the grant of summary judgment that was entered in favor of plaintiff school district because plaintiff did not have vested rights in the annexation agreements to which defendant village was a party.


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