1010 Lake Shore Ass'n v. Deutsche Bank Nat'l Trust Co., 2015 IL 118372 (Ill. 2015). · Go Syfert
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1010 Lake Shore Ass'n v. Deutsche Bank Nat'l Trust Co., 2015 IL 118372 (Ill. 2015). Cases Citing This Book View Copy Cite
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cited 2× by 1 distinct case · …the fundamental objective of statutory construction is to ascertain and give effect to the intent of the legislature. the most reliable indicator of legislative intent is the statutory language, given its plain and ordinary meaning. at p. 21 ≈ altered
355 citation events (355 in the last 25 years) across 4 distinct courts.
Strongest positive: Stewart v. Northwestern Mutual Life Insurance Co. (ilnd, 2016-04-18)
Treatment trajectory · 2015 → 2026 · click a year to view as-of
2015 2020 2026
Top citers, strongest first. 40 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) Stewart v. Northwestern Mutual Life Insurance Co. (2×)
N.D. Ill. · 2016 · signal: see · quote attribution · 2 verbatim quotes · confidence high
the fundamental objective of statutory construction is to ascertain and give effect to the intent of the legislature. the most reliable indicator of legislative intent is the statutory language, given its plain and ordinary meaning.
examined Cited as authority (rule) Tiedemann v. Tiedemann (3×) also: Cited "see"
Ill. App. Ct. · 2025 · confidence medium
“Each word, clause, and sentence of a statute must be given a reasonable construction, and no term should be rendered superfluous.” Id. (citing 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 21).
discussed Cited as authority (rule) Menard, Inc. v. Illinois Farmers Insurance Co.
Ill. App. Ct. · 2024 · confidence medium
Recognizing that fundamental distinction is critical when considering any forfeiture argument. ¶ 75 Menards’ argument further demonstrates its misunderstanding of forfeiture by asserting that raising a new “argument” on appeal “results in forfeiture of that issue.” That assertion improperly conflates the distinct legal concepts of “issues” and “arguments.” In support, Menards cites In re Marriage of Farrell, 2017 IL App (1st) 170611, ¶ 24 (IRMO Farrell), which stated, “ ‘It is well settled that an unsuccessful party may not advance a new theory of recovery on appeal’ …
discussed Cited as authority (rule) People v. Dobbins
Ill. App. Ct. · 2024 · confidence medium
Id. (“We require parties to preserve issues or claims for appeal; we do not require them to limit their arguments here to the same arguments that were made below.”); 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 18 (same).
discussed Cited as authority (rule) Shaw v. U.S. Financial Life Insurance
Ill. App. Ct. · 2022 · confidence medium
“The fundamental objective of statutory construction is to ascertain and give effect to the intent of the legislature.” 1010 Lake 12 No. 1-21-1533 Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 21 (citing Bettis v. Marsaglia, 2014 IL 117050, ¶ 13 ).
discussed Cited as authority (rule) In re Marriage of Rexroat
Ill. App. Ct. · 2022 · confidence medium
“Issues not raised in either the trial court or the appellate court are forfeited.” 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 (citing WISAM 1, Inc. v. Illinois Liquor Control Comm’n, 2014 IL 116173 , ¶ 23). -7- ¶ 22 A trial court’s discovery decisions are reviewed for abuse of discretion.
examined Cited as authority (rule) Dartt v. Pegman (3×)
Ill. App. Ct. · 2022 · confidence medium
“Our review is strictly limited to the certified question[ ] presented; we do not render any opinion on the propriety of any underlying rulings of the trial court.” Id. ¶ 12 Section 2-610 of the Code provides, in relevant part: “(a) Every answer and subsequent pleading shall contain an explicit admission or denial of each allegation of the pleading to which it relates. (b) Every allegation, *** not explicitly denied is admitted, unless the party states in his or her pleading that he or she has no knowledge thereof sufficient to form a belief, and attaches an affidavit of the truth of th…
examined Cited as authority (rule) Soucek v. Breath of Life Professional Services, NFP (3×)
Ill. App. Ct. · 2021 · confidence medium
Plain Language ¶ 52 “The fundamental objective of statutory construction is to ascertain and give effect to the intent of the legislature.” 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 21 (citing Bettis v. Marsaglia, 2014 IL 117050, ¶ 13 ).
examined Cited as authority (rule) In re Estate of Crawford (4×) also: Cited "see"
Ill. App. Ct. · 2021 · confidence medium
“The fundamental objective of statutory construction is to ascertain and give effect to the intent of the legislature.” 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 21 (citing Bettis v. Marsaglia, 2014 IL 117050, ¶ 13 ).
discussed Cited as authority (rule) In re Marriage of Dynako (2×)
Ill. App. Ct. · 2020 · confidence medium
After hearing the parties’ arguments, the court found that it “does not have the ability to modify Respondent’s obligation to pay Petitioner maintenance as set forth in the parties’ Judgment for Dissolution of Marriage entered on February 8, 2016, pursuant to Section 502(f) of the Illinois Marriage and Dissolution of Marriage Act.” Accordingly, the court denied respondent’s motion, further finding that there was no just reason to delay enforcement or appeal of the order. ¶ 18 On October 15, 2019, respondent filed a notice of appeal, and this appeal follows. ¶ 19 ANALYSIS ¶ 20 On…
examined Cited as authority (rule) In re Marriage of Dynako (3×)
Ill. App. Ct. · 2020 · confidence medium
After hearing the parties’ arguments, the court found that it “does not have the ability to modify Respondent’s obligation to pay Petitioner maintenance as set forth in the parties’ Judgment for Dissolution of Marriage entered on February 8, 2016, pursuant to Section 502(f) of the Illinois Marriage and Dissolution of Marriage Act.” Accordingly, the court denied respondent’s motion, further finding that there was no just reason to delay enforcement or appeal of the order. ¶ 18 On October 15, 2019, respondent filed a notice of appeal, and this appeal follows. ¶ 19 ANALYSIS ¶ 20 On…
discussed Cited as authority (rule) Nationstar Mortgage LLC v. Jones (2×)
Ill. App. Ct. · 2020 · confidence medium
Our review of the record reveals that defendant never asserted a violation of Rule 191(a) before the circuit court and thus the circuit court was deprived of the opportunity to correct any such errors. 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 (The purpose of the forfeiture rule “is to encourage parties to raise issues in the trial court, thus ensuring both that the trial court is given an opportunity to correct any errors prior to appeal and that a party does not obtain a reversal through his or her own inaction.”).
discussed Cited as authority (rule) In re Adoption of B.W.
Ill. App. Ct. · 2020 · confidence medium
Furthermore, because the record in the adoption case does not indicate that respondent raised his request for a stay in the trial court, we must conclude that respondent has forfeited any argument on appeal as to whether a stay should have been granted. 12 See 1010 Lake Shore Ass'n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶¶ 14-15 (indicating that issues not raised in the trial court are generally forfeited on appeal). ¶ 26 Second, as for respondent’s due process claim, that same type of claim has already been analyzed and rejected by the United States Supreme Court and by oth…
discussed Cited as authority (rule) Cassidy v. China Vitamins, LLC
Ill. · 2019 · confidence medium
Contrary to China Vitamins’ claim, by adhering to the legislature’s distinctive linguistic choices in subsections (b)(3) and (b)(4), the appellate court did not improperly rewrite the statute in an act “tantamount to legislation by litigation.” Because we must review the express limitations in the relevant provisions as written, we remain unpersuaded by China Vitamins’ final statutory construction argument. ¶ 25 To further ground our construction of section 2-621(b), we also consider the fundamental public policies underlying our legislature’s enactment of Illinois’s strict prod…
discussed Cited as authority (rule) Cassidy v. China Vitamins, LLC
Ill. · 2018 · confidence medium
Contrary to China Vitamins’ claim, by adhering to the legislature’s distinctive linguistic choices in subsections (b)(3) and (b)(4), the appellate court did not improperly rewrite the statute in an act “tantamount to legislation by litigation.” Because we must review the express limitations in the relevant provisions as written, we remain unpersuaded by China Vitamins’ final statutory construction argument. ¶ 25 To further ground our construction of section 2-621(b), we also consider the fundamental public policies underlying our legislature’s enactment of Illinois’s strict prod…
discussed Cited as authority (rule) In re Marriage of Farrell
Ill. App. Ct. · 2018 · confidence medium
App. 3d 117, 123 (1999)), and that doing so results in forfeiture of that issue (see, e.g., 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 (issues not raised in the trial court are forfeited); Stuckey v. Renaissance at Midway, Inc., 2015 IL App (1st) 143111, ¶ 30 (finding it would be improper to address an argument raised for the first time on appeal)).
discussed Cited as authority (rule) In re Marriage of Farrell
Ill. App. Ct. · 2018 · confidence medium
App. 3d 117, 123 (1999)), and that doing so results in forfeiture of that issue (see, e.g., 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 (issues not raised in the trial court are forfeited); Stuckey v. Renaissance at Midway, Inc., 2015 IL App (1st) 143111, ¶ 30 (finding it would be improper to address an argument raised for the first time on appeal)).
examined Cited as authority (rule) Siena at Old Orchard Condominium Association v. Siena at Old Orchard, LLC (3×)
Ill. App. Ct. · 2017 · confidence medium
The Act does not allow for such a provision.” We find the trial court’s reasoning, and the Association’s arguments, persuasive. ¶ 67 “The fundamental objective of statutory construction is to ascertain and give effect to the intent of the legislature.” 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 21 (citing Bettis v. Marsaglia, 2014 IL 117050, ¶ 13 ).
discussed Cited as authority (rule) Wells Fargo Bank, N.A. v. Maka
Ill. App. Ct. · 2017 · confidence medium
It is well settled that a party that does not raise an issue in the trial court forfeits that issue and may not raise it for the first time on appeal. 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 (declining to consider an argument that party failed to raise before the trial and appellate courts).
discussed Cited as authority (rule) In re Marriage of Goesel
Ill. App. Ct. · 2017 · confidence medium
The legislature’s use of the term “available” implies that some funds may be “unavailable.” 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 21 (“reasonable construction must be given to each word, clause, and sentence of a statute, and no term should be rendered superfluous”).
examined Cited as authority (rule) Siena at Old Orchard Condominium Association v. Siena at Old Orchard, LLC (3×)
Ill. App. Ct. · 2017 · confidence medium
The Act does not allow for such a provision.” We find the trial court’s reasoning, and the Association’s arguments, persuasive. ¶ 67 “The fundamental objective of statutory construction is to ascertain and give effect to the intent of the legislature.” 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 21 (citing Bettis v. Marsaglia, 2014 IL 117050, ¶ 13 ).
discussed Cited as authority (rule) Wells Fargo Bank, N.A. v. Maka
Ill. App. Ct. · 2017 · confidence medium
It is well settled that a party that does not raise an issue in the trial court forfeits that issue and may not raise it for the first time on appeal. 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 (declining to consider an argument that party failed to raise before the trial and appellate courts).
discussed Cited as authority (rule) In re Marriage of Goesel
Ill. App. Ct. · 2017 · confidence medium
The legislature’s use of the term “available” implies that some funds may be “unavailable.” 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 21 (“reasonable construction must be given to each word, clause, and sentence of a statute, and no term should be rendered superfluous”).
discussed Cited as authority (rule) Thompson v. N.J.
Ill. App. Ct. · 2016 · confidence medium
App. 3d 117, 123 (1999)), and that doing so results in forfeiture of that issue (see, e.g., 1010 Lake Shore Ass'n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 (issues not raised in the trial court are forfeited); Stuckey v. Renaissance at Midway, 2015 IL App (1st) 143111, ¶ 30 (finding it would be improper to address an argument raised for the first time on appeal)).
examined Cited as authority (rule) Wing Street of Arlington Heights Condominium Asssociation v. Kiss the Chef Holdings, LLC (3×) also: Cited "see", Cited "see, e.g."
Ill. App. Ct. · 2016 · confidence medium
"The most reliable indicator of legislative intent is the statutory language, given its plain and ordinary meaning." 1010 Lake Shore, 2015 IL 118372, ¶ 21 (citing State Building Venture v. O'Donnell, 239 Ill. 2d 151, 160 (2010)); see also In re Marriage of Turk, 2014 IL 116730, ¶ 15 . "[W]hen the language of the statute is clear, it must be applied as written without resort to aids or tools of interpretation." (Internal quotation marks omitted.) JPMorgan Chase Bank, N.A. v. Earth Foods, Inc., 238 Ill. 2d 455, 461 (2010); see also Turk, 2014 IL 116730, ¶ 15 .
cited Cited "see" In re Marriage of Panchev
Ill. App. Ct. · 2026 · signal: see · confidence high
See 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372 , ¶ 14 (contentions not raised in the trial court are forfeited and may not be raised on appeal). ¶ 26 III.
discussed Cited "see" Nikoloff v. Northop Grumman Systems Corp.
Ill. App. Ct. · 2026 · signal: see · confidence high
See 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372 , ¶ 14. ¶ 30 In the proceedings below, the plaintiff never affirmatively argued to the trial court or sought a ruling from it that section 1-25(b) of the Workplace Transparency Act applied in this case as a basis for denying arbitration.
discussed Cited "see" In re Marriage of Qureshi
Ill. App. Ct. · 2023 · signal: see · confidence high
See 1010 Lake Shore Association v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 . ¶ 24 Here, Muhammad’s failure to appear at the various trial-level hearings necessarily resulted in a failure to raise before the trial court all of his arguments that he now raises here.
cited Cited "see" In re K.J.
Ill. App. Ct. · 2022 · signal: see · confidence high
See 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 (citing People v. Denson, 2014 IL 116231, ¶ 13 ).
cited Cited "see" PNC Bank, National Ass'n v. Kusmierz
Ill. · 2022 · signal: see · confidence high
See 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372 , ¶¶ 14-15.
cited Cited "see" PNC Bank, National Ass'n v. Kusmierz
Ill. · 2022 · signal: see · confidence high
See 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372 , ¶¶ 14-15.
cited Cited "see" Medponics Illinois LLC v. Dept. of Agriculture
Ill. · 2021 · signal: see · confidence high
See 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 (issues not raised in the circuit court or appellate court are forfeited).
discussed Cited "see" In re Marriage of Dragoi-Zulicic
Ill. App. Ct. · 2021 · signal: see · confidence high
See 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 (arguments not raised on appeal are forfeited); Franciscan Communities, Inc. v. Hamer, 2012 IL App (2d) 110431, ¶ 19 (arguments raised for the first time in reply briefs are forfeited). ¶ 18 In any event, we find that the court appropriately treated Priscilla’s motion as a motion to enforce part of the dissolution judgment.
discussed Cited "see" In re Marriage of Dragoi-Zulicic
Ill. App. Ct. · 2021 · signal: see · confidence high
See 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 (arguments not raised on appeal are forfeited); Franciscan Communities, Inc. v. Hamer, 2012 IL App (2d) 110431, ¶ 19 (arguments raised for the first time in reply briefs are forfeited). ¶ 18 In any event, we find that the court appropriately treated Priscilla’s motion as a motion to enforce part of the dissolution judgment.
discussed Cited "see" Shannon Court Condominium Ass'n v. Armada Express, Inc.
Ill. App. Ct. · 2020 · signal: see · confidence high
See V&T Investment Corp. v. West Columbia Place Condominium Ass’n, 2018 IL App (1st) 170436, ¶ 30 . ¶ 18 Having found that Armada paid postsale assessments for Unit 101 for the period beginning in the month following the foreclosure sale, it follows that, pursuant to the plain language of section 9(g)(3) of the Act, the payment confirmed the extinguishment of any lien on Unit 101 -4- in favor of the Association created under section 9(g)(1) of the Act by reason of the Voelkers’ failure to pay assessments. 1010 Lake Shore Ass’n, 2015 IL 118372, ¶ 24 ; V&T Investment Corp., 2018 IL App …
discussed Cited "see" Goldman v. Kalish
Ill. App. Ct. · 2020 · signal: see · confidence high
See 1010 Lake Shore Ass'n, 2015 IL 118372, ¶ 15 . ¶ 19 Appellants then allege that because of the missing witnesses, the circuit court did not consider Appellants’ evidence and improperly denied Appellants’ motion for a continuance.
discussed Cited "see" Hometown Condominium Association No. 2 v. Mohammed (2×)
Ill. App. Ct. · 2018 · signal: see · confidence high
See Foutch , 99 Ill. 2d at 392 , 76 Ill.Dec. 823 , 459 N.E.2d 958 . ¶ 24 The parties mostly disregard the incompleteness of the record and focus on the interpretation of section 9 of the Act, which we review de novo . 1010 Lake Shore , 2015 IL 118372 , ¶ 21, 398 Ill.Dec. 95 , 43 N.E.3d 1005 .
discussed Cited "see" In re Jeanette L.
Ill. App. Ct. · 2017 · signal: see · confidence high
App. 2d 204, 210 (1960); see -4- also 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 (“The purpose of this court’s forfeiture rules is to encourage parties to raise issues in the trial court, thus ensuring both that the trial court is given an opportunity to correct any errors prior to appeal and that a party does not obtain a reversal through his or her own inaction.” (citing People v. Denson, 2014 IL 116231, ¶ 13 )).
discussed Cited "see" Vantage Hospitality Group, Inc. v. Q Ill Development (2×)
Ill. App. Ct. · 2016 · signal: see · confidence high
See 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 , 43 N.E.3d 1005 (“Issues not raised in either the trial court or the appellate court are forfeited.”); Depart- ment of Human Services v. Porter, 396 Ill.
discussed Cited "see, e.g." In re Jeanette L.
Ill. App. Ct. · 2017 · signal: see also · confidence medium
App. 2d 204, 210 (1960); see also 1010 Lake Shore Ass’n v. Deutsche Bank National Trust Co., 2015 IL 118372, ¶ 14 (“The purpose of this court’s forfeiture rules is to encourage parties to raise issues in the trial court, thus ensuring both that the trial court is given an opportunity to correct any errors prior to appeal and that a party does not obtain a reversal through his or her own inaction.”) (citing People v. Denson, 2014 IL 116231, ¶ 13 ).
Retrieving the full opinion text from the archive…
1010 Lake Shore Association
v.
Deutsche Bank National Trust Company
118372.
Illinois Supreme Court.
Dec 3, 2015.
2015 IL 118372
Cited by 21 opinions  |  Unpublished

2015 IL 118372

IN THE SUPREME COURT OF THE STATE OF ILLINOIS

(Docket No. 118372)

1010 LAKE SHORE ASSOCIATION, Appellee, v. DEUTSCHE BANK NATIONAL TRUST COMPANY, as Trustee for Loan Tr 2004-1, Asset-Backed Certificates, Series 2004-1, Appellant.

Opinion filed December 3, 2015.

JUSTICE KILBRIDE delivered the judgment of the court, with opinion.

Chief Justice Garman and Justices Freeman, Thomas, Karmeier, Burke, and Theis concurred in the judgment and opinion.

OPINION

¶1 The issue in this case involves the construction of section 9(g)(3) of the Condominium Property Act (Act) (765 ILCS 605/9(g)(3) (West 2008)). The appellate court held that under section 9(g)(3), defendant Deutsche Bank National Trust Company failed to confirm the extinguishment of the plaintiff condominium association’s lien created when the prior unit owner did not pay common expense assessments. 2014 IL App (1st) 130962. For the following reasons, we affirm the appellate court’s judgment.

¶2 I. BACKGROUND

¶3 Defendant Deutsche Bank National Trust Company, as Trustee for Loan Tr 2004-1, Asset-Backed Certificates, Series 2004-1, purchased a condominium unit at a judicial foreclosure sale on June 17, 2010. On March 27, 2012, plaintiff 1010 Lake Shore Association mailed defendant a demand for payment of the unit’s assessments for common expenses.

¶4 On May 17, 2012, plaintiff filed a complaint seeking possession of the property, an award of all unpaid assessments, attorney fees, and costs. In its complaint, plaintiff alleged that defendant owed $62,530.81 in assessments as of March 27, 2012.

¶5 After defendant filed its answer, plaintiff moved for summary judgment arguing there were no questions of material fact on the amount owed or defendant’s failure to pay the assessments. Based on section 9(g)(3) of the Act (765 ILCS 605/9(g)(3) (West 2008)), plaintiff asserted that the lien against the property for the prior owner’s unpaid assessments had not been extinguished because defendant failed to pay the assessments accruing after it purchased the unit at the judicial foreclosure sale. Consequently, plaintiff alleged defendant was also required to pay those prior assessments.

¶6 Plaintiff attached to its summary judgment motion an affidavit of its property manager, Mary Morrison. Morrison averred that: (1) no assessment payments were made for the unit since July 1, 2010; (2) the outstanding balance was $67,935.16 as of August 8, 2012; (3) assessments accrued at the rate of $1,041.87 per month; and (4) late fees were $50 per month.

¶7 Defendant responded that it could not be held liable under section 9(g)(3) of the Act for unpaid assessments that accrued before it purchased the unit at the judicial foreclosure sale. Defendant asserted those prior assessments accounted for more than $43,000 of the total. Defendant also contended that any lien relating to the preforeclosure assessments was extinguished in the foreclosure action and there was a genuine issue of material fact on the amount of assessments incurred after it purchased the unit. Following a hearing, the trial court granted summary judgment for plaintiff in the amount of $70,018.90 and entered an order awarding plaintiff possession of the property.

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¶8 On appeal, defendant contended that the trial court misconstrued section 9(g)(3) of the Act. Defendant argued that under section 9(g)(3) a purchaser of a condominium unit at a foreclosure sale is only required to pay the common expenses that accrue following the sale. The appellate court agreed that the first sentence of section 9(g)(3) only requires the purchaser to pay assessments from the first day of the month following the sale. The second sentence, however, provides that making those assessment payments “confirms the extinguishment” of the lien created when the prior owner failed to pay assessments. 2014 IL App (1st) 130962, ¶ 12. The appellate court determined that “under the plain language of section 9(g)(3), a lien created under section 9(g)(1) for unpaid assessments by a previous owner is not fully extinguished following a judicial foreclosure and sale until the purchaser makes a payment for assessments incurred after the sale.” 2014 IL App (1st) 130962, ¶ 12.

¶9 The appellate court found that the lien for the prior owner’s unpaid assessments was not extinguished because defendant failed to pay the assessments following the foreclosure sale. 2014 IL App (1st) 130962, ¶ 17. The appellate court concluded there was no genuine issue of material fact on the amount owed by defendant, and the trial court did not err in granting summary judgment for plaintiff. 2014 IL App (1st) 130962, ¶ 19. The trial court’s judgment was, therefore, affirmed. 2014 IL App (1st) 130962, ¶ 31.

¶ 10 Justice Liu dissented, asserting that section 9(g)(3) of the Act and section 15-1509(c) of the Illinois Mortgage Foreclosure Law (Foreclosure Law) (735 ILCS 5/15-1509(c) (West 2008)), establish a complementary procedure for extinguishing liens held by a condominium association. Section 15-1509(c) of the Foreclosure Law applies to bar any claim based on a lien when the condominium association has been named as a party to a foreclosure action. 2014 IL App (1st) 130962, ¶ 38 (Liu, J., dissenting). Section 9(g)(3) of the Act applies when a condominium association is not named as a party to the foreclosure action, and it provides a way for a foreclosure sale purchaser to extinguish a preexisting lien that survives the foreclosure action. To extinguish the lien under section 9(g)(3), the purchaser must pay the assessments that accrue after the sale. 2014 IL App (1st) 130962, ¶ 38 (Liu, J., dissenting). The dissenting justice concluded that plaintiff’s lien based on the assessments owed by the prior owner was extinguished in the foreclosure action because plaintiff “was purportedly a party in [that] action.” 2014 IL App (1st) 130962, ¶ 39 (Liu, J., dissenting).

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¶ 11 We allowed defendant’s petition for leave to appeal. Ill. S. Ct. R. 315 (eff. May 1, 2013). We also allowed the Federal National Mortgage Association and the Condominium Association Institute to file amicus curiae briefs. Ill. S. Ct. R. 345 (eff. Sept. 20, 2010).

¶ 12 II. ANALYSIS

¶ 13 Defendant raises two issues on appeal to this court. First, defendant raises the argument on the construction of section 9(g)(3) of the Act, asserting that issue “has been the crux of this case since [plaintiff] filed its motion for summary judgment.” Second, defendant challenges the remedy chosen by plaintiff, contending the appellate court erred in allowing plaintiff to enforce the lien through a personal money judgment action rather than a lien foreclosure proceeding. Defendant contends that the appropriate remedy is for plaintiff to file a lien foreclosure action rather than a forcible entry and detainer action under section 9.2(a) of the Act (765 ILCS 605/9.2(a) (West 2008)) and the forcible entry and detainer statute (735 ILCS 5/9-101 et seq. (West 2008)).

¶ 14 Plaintiff responds that defendant’s argument challenging the remedy is forfeited for failure to raise it in the trial court. Issues not raised in either the trial court or the appellate court are forfeited. WISAM 1, Inc. v. Illinois Liquor Control Comm’n, 2014 IL 116173, ¶ 23. The purpose of this court’s forfeiture rules is to encourage parties to raise issues in the trial court, thus ensuring both that the trial court is given an opportunity to correct any errors prior to appeal and that a party does not obtain a reversal through his or her own inaction. People v. Denson, 2014 IL 116231, ¶ 13.

¶ 15 Defendant did not present any argument in the trial court challenging plaintiff’s use of the forcible entry and detainer remedy under section 9.2 of the Act. In fact, the issue was never raised until after the appellate court issued its decision. At that point, defendant filed a petition for rehearing raising the question for the first time. The trial court did not have an opportunity to consider and rule upon this question. Defendant, therefore, forfeited this issue by failing to timely raise it in the trial court.

¶ 16 We now address the remaining issue in this appeal on the construction of section 9(g)(3) of the Act. Defendant asserts its argument “mirrors” the appellate

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court dissent. Defendant contends that subsection 9(g)(3) provides foreclosure sale purchasers an alternative means of extinguishing a condominium association’s lien if the foreclosing party failed to extinguish the lien under the Foreclosure Law (735 ILCS 5/15-1509(c) (West 2008)). Defendant maintains that the Foreclosure Law extinguishes assessment liens when the condominium association is joined as a party to the foreclosure action and section 9(g)(3) of the Act permits a foreclosure sale purchaser to extinguish a surviving lien by paying the assessments coming due after the sale. Defendant asserts it joined plaintiff in the foreclosure action and, therefore, plaintiff’s lien was extinguished under the Foreclosure Law.

¶ 17 Initially, plaintiff contends defendant forfeited its argument relying on canons of statutory construction because it did not raise that argument in either the trial or the appellate court. Plaintiff argues that defendant failed to even acknowledge the second sentence of section 9(g)(3) in the trial and appellate courts, and it cannot now argue that section 9(g)(3) conflicts with the Foreclosure Law.

¶ 18 Defendant’s contention based on canons of statutory construction is merely one argument addressing the issue of the proper construction of section 9(g)(3). Even if defendant did not make that specific argument in the trial or appellate court, defendant has consistently disputed the issue of statutory construction. This court only requires parties to preserve issues or claims for appeal. They are not required to limit their arguments in this court to the same ones made in the trial and appellate courts. Brunton v. Kruger, 2015 IL 117663, ¶ 76. Accordingly, defendant's statutory construction argument is not forfeited.

¶ 19 On the merits, plaintiff contends that section 9(g)(3) of the Act imposes an additional step in extinguishing a condominium association’s lien. The additional step simply requires the foreclosure sale purchaser to pay its common expense assessments following the sale. Plaintiff maintains that by refusing to pay any postforeclosure sale assessments, defendant failed to confirm the extinguishment of plaintiff’s lien for the unpaid assessments of the prior owner.

¶ 20 This appeal arises from the trial court’s order granting plaintiff summary judgment. Summary judgment is proper when “the pleadings, depositions, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” 735 ILCS 5/2-1005(c) (West 2008). The interpretation of a statute is a matter of law appropriate for summary judgment. Lake County Grading Co. v.

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Village of Antioch, 2014 IL 115805, ¶ 18. We review a trial court’s summary judgment ruling de novo. Nationwide Financial, LP v. Pobuda, 2014 IL 116717, ¶ 24.

¶ 21 In resolving this appeal, we must construe the terms of the Act and the Foreclosure Law. Questions of statutory construction are also reviewed de novo. Skaperdas v. Country Casualty Insurance Co., 2015 IL 117021, ¶ 15. The fundamental objective of statutory construction is to ascertain and give effect to the intent of the legislature. Bettis v. Marsaglia, 2014 IL 117050, ¶ 13. The most reliable indicator of legislative intent is the statutory language, given its plain and ordinary meaning. State Building Venture v. O’Donnell, 239 Ill. 2d 151, 160 (2010). A reasonable construction must be given to each word, clause, and sentence of a statute, and no term should be rendered superfluous. Slepicka v. Illinois Department of Public Health, 2014 IL 116927, ¶ 14.

¶ 22 We begin by reviewing the relevant provisions of the Act. Section 9(g)(1) provides:

“(1) If any unit owner shall fail or refuse to make any payment of the common expenses or the amount of any unpaid fine when due, the amount thereof *** shall constitute a lien on the interest of the unit owner in the property prior to all other liens and encumbrances, recorded or unrecorded, except only (a) taxes, special assessments and special taxes theretofore or thereafter levied by any political subdivision or municipal corporation of this State and other State or federal taxes which by law are a lien on the interest of the unit owner prior to preexisting recorded encumbrances thereon and (b) encumbrances on the interest of the unit owner recorded prior to the date of such failure or refusal which by law would be a lien thereon prior to subsequently recorded encumbrances. Any action brought to extinguish the lien of the association shall include the association as a party.” 765 ILCS 605/9(g)(1) (West 2008).

¶ 23 The plain language of section 9(g)(1), therefore, creates a lien in favor of a condominium association upon the failure or refusal of a unit owner to pay common expense assessments. Section 9(g)(3) states that:

“(3) The purchaser of a condominium unit at a judicial foreclosure sale, or a mortgagee who receives title to a unit by deed in lieu of foreclosure or judgment by common law strict foreclosure or otherwise takes possession pursuant to -6-

court order under the Illinois Mortgage Foreclosure Law, shall have the duty to pay the unit’s proportionate share of the common expenses for the unit assessed from and after the first day of the month after the date of the judicial foreclosure sale, delivery of the deed in lieu of foreclosure, entry of a judgment in common law strict foreclosure, or taking of possession pursuant to such court order. Such payment confirms the extinguishment of any lien created pursuant to paragraph (1) or (2) of this subsection (g) by virtue of the failure or refusal of a prior unit owner to make payment of common expenses, where the judicial foreclosure sale has been confirmed by order of the court, a deed in lieu thereof has been accepted by the lender, or a consent judgment has been entered by the court.” 765 ILCS 605/9(g)(3) (West 2008).

¶ 24 The first sentence of section 9(g)(3) plainly requires a foreclosure sale purchaser to pay common expense assessments beginning in the month following the foreclosure sale. The second sentence provides an incentive for prompt payment of those postforeclosure sale assessments, stating “[s]uch payment confirms the extinguishment of any lien created” under subsection 9(g)(1) by the prior unit owner’s failure to pay assessments. “[C]onfirm” means “[t]o give formal approval to,” “[t]o verify or corroborate,” or “[t]o make firm or certain.” Black’s Law Dictionary 318 (8th ed. 2004). “Extinguishment” is defined as “[t]he cessation or cancellation of some right or interest.” Black’s Law Dictionary 623 (8th ed. 2004). Accordingly, under the plain language of section 9(g)(3), the payment of postforeclosure sale assessments formally approves and makes certain the cancellation of the condominium association’s lien.

¶ 25 By requiring the foreclosure sale purchaser to “confirm[ ] the extinguishment” of the lien, section 9(g)(3) plainly mandates an additional step beyond the extinguishment of the lien in a foreclosure action. Section 9(g)(3) sets forth that additional step, stating the extinguishment is confirmed by payment of postforeclosure sale assessments.

¶ 26 Contrary to defendant’s argument, the language of section 9(g)(3) cannot be construed as an alternative means for foreclosure sale purchasers to extinguish a condominium association’s lien when the association was not joined as a party to the foreclosure action. Section 9(g)(1) creates an association’s lien upon the failure or refusal of a unit owner to make common expense payments when due, and that section states, “[a]ny action brought to extinguish the lien of the association shall include the association as a party.” Thus, section 9(g)(1) is very specific on the -7-

method for extinguishing an association’s lien created by the prior unit owner’s failure to pay assessments. Section 9(g)(1) states an action to extinguish the lien “shall include the association as a party.” The statute does not provide that a foreclosure sale purchaser may extinguish the lien by simply making postforeclosure sale assessment payments.

¶ 27 Additionally, defendant’s argument is contrary to the plain language of section 9(g)(3). Section 9(g)(3) requires payment of postforeclosure sale assessments to “confirm the extinguishment” of the lien. The plain language of section 9(g)(3) assumes that the lien has already been extinguished by including the association as a party to a foreclosure action. Section 9(g)(3) provides an additional step to confirm or formally approve the extinguishment by paying the postforeclosure sale assessments. We conclude that defendant’s proposed construction of section 9(g)(3)—that it provides an alternative method to extinguish the condominium association’s lien—is contrary to the express language of sections 9(g)(1) and 9(g)(3). Significantly, defendant does not provide any other proposed construction for the second sentence of section 9(g)(3).

¶ 28 Defendant contends, however, that sections 9(g)(4) and 9(g)(5) show the legislature did not intend for mortgagees to be liable for their borrower’s prior unpaid assessments. Defendant asserts that in those subsections, the legislature enacted a rule allowing condominium associations to collect up to six months of unpaid assessments incurred prior to the foreclosure sale, but expressly exempted mortgagees from the requirement to pay those assessments. Defendant argues the six-month rule in sections 9(g)(4) and 9(g)(5) shows the legislature did not intend foreclosure sale purchasers to be liable for all unpaid assessments incurred prior to the sale.

¶ 29 Section 9(g)(4) provides:

“(4) The purchaser of a condominium unit at a judicial foreclosure sale, other than a mortgagee, who takes possession of a condominium unit pursuant to a court order or a purchaser who acquires title from a mortgagee shall have the duty to pay the proportionate share, if any, of the common expenses for the unit which would have become due in the absence of any assessment acceleration during the 6 months immediately preceding institution of an action to enforce the collection of assessments, and which remain unpaid by the owner during whose possession the assessments accrued. If the outstanding

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assessments are paid at any time during any action to enforce the collection of assessments, the purchaser shall have no obligation to pay any assessments which accrued before he or she acquired title.” 765 ILCS 605/9(g)(4) (West 2008).

¶ 30 Section 9(g)(5) provides, in pertinent part:

“(5) The notice of sale of a condominium unit under subsection (c) of Section 15-1507 of the Code of Civil Procedure shall state that the purchaser of the unit other than a mortgagee shall pay the assessments and the legal fees required by subdivisions (g)(1) and (g)(4) of Section 9 of this Act.” 765 ILCS 605/9(g)(5) (West 2008).

¶ 31 We believe sections 9(g)(4) and 9(g)(5) are consistent with our interpretation of section 9(g)(3). Together, those provisions allow condominium associations to recover a portion of the prior owner’s unpaid assessments and to ensure payment of assessments that accrue following the foreclosure sale.

¶ 32 Specifically, sections 9(g)(4) and 9(g)(5) apply to foreclosure sale purchasers other than mortgagees and to purchasers acquiring title from a mortgagee. Those third-party purchasers are required to pay a prior owner’s unpaid assessments that accrued during the six months preceding an action to collect assessments. Section 9(g)(5) requires the notice of the foreclosure sale to state that a purchaser other than a mortgagee must pay those prior unpaid assessments. Sections 9(g)(4) and 9(g)(5), therefore, allow condominium associations to recover a portion of the prior owner’s unpaid assessments from the new owner.

¶ 33 Section 9(g)(3), in contrast, applies to all foreclosure sale purchasers, including mortgagees, and it simply requires the purchaser to pay assessments beginning the month following the foreclosure sale to confirm the extinguishment of the lien created by the prior owner’s failure to pay assessments. Section 9(g)(3) does not require a foreclosure sale purchaser to pay any of the prior owner’s unpaid assessments if the purchaser pays the assessments coming due following the sale. Thus, section 9(g)(3) ensures payment of assessments accruing after the foreclosure sale. Under section 9, mortgagees may be exempted from liability for the prior owner’s unpaid assessments, but only if the mortgagee pays the assessments coming due following its purchase of the unit at the foreclosure sale.

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¶ 34 We further note that although sections 9(g)(1) and 9(g)(3) do not require notice to defendant of the prior owner’s unpaid assessments, the terms of section 9(g)(1) effectively put mortgagees on notice of the potential for unrecorded association liens. Section 9(g)(1) states any action to extinguish those liens must include the association as a party. Additionally, the Act allows an encumbrancer “from time to time [to] request in writing a written statement *** setting forth the unpaid common expenses with respect to the unit covered by his encumbrance.” 765 ILCS 605/9(j) (West 2008). Thus, a mortgagee may protect its interest by requesting notice of unpaid assessments, joining the association as a party to a foreclosure action, and paying assessments that accrue following its purchase of a property at a foreclosure sale.

¶ 35 Defendant also argues that the appellate court’s construction of section 9(g)(3) conflicts with section 15-1509(c) of the Foreclosure Law. Section 15-1509(c) provides that foreclosure of a mortgage extinguishes all junior lien interests of parties joined in the foreclosure action. Defendant maintains plaintiff’s lien was extinguished in the foreclosure action and it cannot be revived to “confirm the extinguishment” under the Act.

¶ 36 Section 15-1509(c) of the Foreclosure Law provides, in pertinent part:

“Any vesting of title *** by deed pursuant to subsection (b) of Section 15-1509, unless otherwise specified in the judgment of foreclosure, shall be an entire bar of (i) all claims of parties to the foreclosure and (ii) all claims of any nonrecord claimant who is given notice of the foreclosure ***.” 735 ILCS 5/15-1509(c) (West 2008).

¶ 37 We presume that several statutes relating to the same subject are governed by a single spirit and policy and that the legislature intended the statutes to be consistent and harmonious. Uldrych v. VHS of Illinois, Inc., 239 Ill. 2d 532, 540 (2011). Even when there is an apparent conflict between statutes, they must be construed in harmony if reasonably possible. Knolls Condominium Ass’n v. Harms, 202 Ill. 2d 450, 459 (2002). Section 9(g)(3) of the Act and section 15-1509(c) of the Foreclosure Law both relate to the foreclosure of condominium units. Accordingly, we presume that the legislature intended the Act and the Foreclosure Law to be consistent and harmonious.

¶ 38 A review of those statutory provisions shows they may be construed consistently. Under section 15-1509(c) of the Foreclosure Law, vesting of title in - 10 -

the purchaser acts as a bar to claims of parties to the foreclosure action, thus extinguishing junior liens. Consistent with the Foreclosure Law, section 9(g)(1) of the Act states that “[a]ny action brought to extinguish the lien of the association shall include the association as a party.” 765 ILCS 605/9(g)(1) (West 2008). Section 9(g)(1), therefore, requires compliance with the Foreclosure Law to extinguish the association’s lien. Section 9(g)(3) then provides an additional step to “confirm the extinguishment” of the association’s lien by requiring payment of postforeclosure sale assessments. By employing the “confirms the extinguishment” language, section 9(g)(3) assumes that the lien has been extinguished under the Foreclosure Law. The plain language of the Act and the Foreclosure Law may, therefore, be reasonably construed together to provide a process for extinguishing and confirming the extinguishment of the association’s lien.

¶ 39 While defendant argues that a mortgagee must be able to extinguish junior lien interests joined in the foreclosure action to convey clear title to a subsequent purchaser, section 9 of the Act does not impede defendant’s ability to provide clear title. Section 9(g)(3) only requires the foreclosure sale purchaser to pay assessments coming due following the foreclosure sale. Payment of those assessments confirms the extinguishment of the lien for the prior owner’s unpaid assessments. Accordingly, defendant’s interest in providing clear title will not be impaired if it complies with section 9(g)(3) and pays the assessments coming due following its purchase of a property at a foreclosure sale.

¶ 40 Given our construction of the statutory provisions, we conclude that the trial court did not err in granting plaintiff summary judgment. While defendant argues that the trial court erred in granting summary judgment because plaintiff’s lien was extinguished under section 15-1509(c) of the Foreclosure Law, the record is not entirely clear that plaintiff was joined as a party to the foreclosure action. Although defendant asserts in its brief that it joined plaintiff as a party, it admits “the underlying foreclosure papers are not of record.”

¶ 41 In any case, even if the record clearly established that defendant joined plaintiff as a party to the foreclosure, defendant failed to confirm the extinguishment of plaintiff’s lien under section 9(g)(3) of the Act. The record shows that defendant purchased the unit at a foreclosure sale on June 17, 2010. The affidavit of plaintiff’s property manager establishes that defendant did not make any assessment payments after purchasing the property at the foreclosure sale. Based on the evidence of record, we conclude that defendant failed to confirm the - 11 - extinguishment of plaintiff’s lien for the prior owner’s unpaid assessments under section 9(g)(3) of the Act.

¶ 42 Defendant does not present any other argument challenging the trial court’s order granting summary judgment. Accordingly, the trial court’s order granting plaintiff summary judgment must be affirmed.

¶ 43 III. CONCLUSION

¶ 44 For the foregoing reasons, the judgments of the circuit and appellate courts are affirmed.

¶ 45 Affirmed.

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