standing is designed to preclude persons doctrine in Illinois

2026“We review the dismissal of a complaint pursuant to section 2-619(a)(9) de novo.” Smith v. Waukegan Park District, 231 Ill. 2d 111 , 115 (2008) (citing Glisson v. City of Marion, 188 Ill. 2d 211, 220 (1999)). ¶ 14 “The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit.” Glisson, 188 Ill. 2d at 221 .

2026“We review the dismissal of a complaint pursuant to section 2-619(a)(9) de novo.” Smith v. Waukegan Park District, 231 Ill. 2d 111 , 115 (2008) (citing Glisson v. City of Marion, 188 Ill. 2d 211, 220 (1999)). ¶ 14 “The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit.” Glisson, 188 Ill. 2d at 221 .

2024Additionally, Knopp argues that the circuit court erred when it did not apply New York law with respect to the PSA. ¶ 25 “The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit.” Raintree Homes, Inc. v. Village of Long Grove, 209 Ill. 2d 248, 262 (2004).

2021App. 3d 465, 468 (2008). ¶ 27 “The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit.” Raintree Homes, Inc. v. Village of Long Grove, 209 Ill. 2d 248, 262 (2004).

2024Our supreme court has stated that the “lack of standing in a civil case is an affirmative defense, which will be waived if not raised in a timely fashion in the trial court.” Greer v. Illinois Housing Development Authority, 122 Ill. 2d 462, 508 (1988).

2021To that end, our supreme court has recognized that Illinois standing law is more liberal than federal law and that “State courts are generally more willing than Federal courts to recognize standing on the part of any plaintiff who shows that he is in fact aggrieved by an administrative decision.” Greer, 122 Ill. 2d at 491 . ¶ 33 The plaintiffs argue that they have met the standing requirements because either they, or their members, own shorefront property on Lake Michigan and use and enjoy both the CAWS and Lake Michigan.

2022App. 3d 722, 745 (2009) (citing Village of Chatham v. County of Sangamon, 216 Ill. 2d 402, 419 (2005)). “ ‘The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit’ ” and “ ‘assures that issues are raised only by those parties with a real interest in the outcome of the controversy.’ ” Mortgage Electronic Registration Systems, Inc. v. Barnes, 406 Ill.

2022App. 3d 722, 745 (2009) (citing Village of Chatham v. County of Sangamon, 216 Ill. 2d 402, 419 (2005)). “ ‘The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit’ ” and “ ‘assures that issues are raised only by those parties with a real interest in the outcome of the controversy.’ ” Mortgage Electronic Registration Systems, Inc. v. Barnes, 406 Ill.

2014However, our Illinois Supreme Court has stated that the “lack of standing in - 12 - a civil case is an affirmative defense, which will be forfeited if not raised in a timely fashion in the trial court.” Greer v. Illinois Housing Development Authority, 122 Ill. 2d 462, 508 (1988); People v. Kelly, 397 Ill.

2014However, our Illinois Supreme Court has stated that the “lack of standing in a civil case is an affirmative defense, which will be forfeited if not raised in a timely fashion in the trial court.” Greer v. Illinois Housing Development Authority, 122 Ill. 2d 462, 508 (1988); People v. Kelly, 397 Ill.

2020“The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit” and “assures that issues are raised only by those parties with a real interest in the outcome of the controversy.” Glisson v. City of Marion, 188 Ill. 2d 211, 221 (1999); see Bayview Loan Servicing, LLC v. Cornejo, 2015 IL App (3d) 140412, ¶ 12 .

2016Defendant contends that plaintiff’s failure to attach an assignment to any of its pleadings along with the fact that the assignment was executed after the lawsuit commenced constitutes the kind of egregious misrepresentation that demonstrates justice was not otherwise done in this case. ¶ 34 “The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit” and “assures that issues are raised only by those parties with a real interest in the outcome of the controversy.” Glisson v. City of Marion, 188 Ill. 2d 211, 221 (1999); see Bayview Loan Ser

2022App. 3d 722, 745 (2009) (citing Village of Chatham v. County of Sangamon, 216 Ill. 2d 402, 419 (2005)). “ ‘The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit’ ” and “ ‘assures that issues are raised only by those parties with a real interest in the outcome of the controversy.’ ” Mortgage Electronic Registration Systems, Inc. v. Barnes, 406 Ill.

2011App.3d 722, 745 , 331 Ill.Dec. 378 , 910 N.E.2d 1134 (2009) (citing Village of Chatham v. County of Sangamon, 216 Ill.2d 402, 419 , 297 Ill.Dec. 249 , 837 N.E.2d 29 (2005)). "`The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing *975 suit'" and "`assures that issues are raised only by those parties with a real interest in the outcome of the controversy.'" Mortgage Electronic Registration Systems, Inc. v. Barnes, 406 Ill.App.3d 1, 6 , 346 Ill.Dec. 118 , 940 N.E.2d 118 (2010) (quoting Glisson, 188 Ill.2d at 221 , 242 Ill.Dec. 79 , 720 N.E.2

2024Reynolds v. Jimmy John’s Enterprises, LLC, 2013 IL App (4th) 120139, ¶ 33 (citing Jackson v. Randle, 2011 IL App (4th) 100790, ¶ 12 ). ¶ 22 “ ‘The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit,’ and ‘assures that issues are raised only by those parties with a real interest in the outcome of the controversy.’ ” Nationwide Advantage Mortgage Co. v. Ortiz, 2012 IL App (1st) 112755, ¶ 24 (quoting Glisson v. City of Marion, 188 Ill. 2d 211, 221 (1999)). “ ‘To have standing, *** the [claimant] must not be merely curious or concerned but

2018Reynolds, 2013 IL App (4th) 120139, ¶ 33 ; Jackson v. Randle, 2011 IL App (4th) 100790, ¶ 12 . “ ‘The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit,’ and ‘assures that issues are raised only by those parties with a real interest in the outcome of the controversy.’ ” Nationwide Advantage Mortgage Co. v. Ortiz, 2012 IL App (1st) 112755, ¶ 24 (quoting Glisson v. City of Marion, 188 Ill. 2d 211, 221 (1999)). ¶ 30 “ ‘To have standing, *** the [claimant] must not be merely curious or concerned but must possess some personal claim, statu

2024Reynolds v. Jimmy John’s Enterprises, LLC, 2013 IL App (4th) 120139, ¶ 33 (citing Jackson v. Randle, 2011 IL App (4th) 100790, ¶ 12 ). ¶ 22 “ ‘The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit,’ and ‘assures that issues are raised only by those parties with a real interest in the outcome of the controversy.’ ” Nationwide Advantage Mortgage Co. v. Ortiz, 2012 IL App (1st) 112755, ¶ 24 (quoting Glisson v. City of Marion, 188 Ill. 2d 211, 221 (1999)). “ ‘To have standing, *** the [claimant] must not be merely curious or concerned but

2018Reynolds, 2013 IL App (4th) 120139, ¶ 33 ; Jackson v. Randle, 2011 IL App (4th) 100790, ¶ 12 . “ ‘The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit,’ and ‘assures that issues are raised only by those parties with a real interest in the outcome of the controversy.’ ” Nationwide Advantage Mortgage Co. v. Ortiz, 2012 IL App (1st) 112755, ¶ 24 (quoting Glisson v. City of Marion, 188 Ill. 2d 211, 221 (1999)). ¶ 30 “ ‘To have standing, *** the [claimant] must not be merely curious or concerned but must possess some personal claim, statu

2024Reynolds v. Jimmy John’s Enterprises, LLC, 2013 IL App (4th) 120139, ¶ 33 (citing Jackson v. Randle, 2011 IL App (4th) 100790, ¶ 12 ). ¶ 22 “ ‘The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit,’ and ‘assures that issues are raised only by those parties with a real interest in the outcome of the controversy.’ ” Nationwide Advantage Mortgage Co. v. Ortiz, 2012 IL App (1st) 112755, ¶ 24 (quoting Glisson v. City of Marion, 188 Ill. 2d 211, 221 (1999)). “ ‘To have standing, *** the [claimant] must not be merely curious or concerned but

2018Reynolds, 2013 IL App (4th) 120139, ¶ 33 ; Jackson v. Randle, 2011 IL App (4th) 100790, ¶ 12 . “ ‘The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit,’ and ‘assures that issues are raised only by those parties with a real interest in the outcome of the controversy.’ ” Nationwide Advantage Mortgage Co. v. Ortiz, 2012 IL App (1st) 112755, ¶ 24 (quoting Glisson v. City of Marion, 188 Ill. 2d 211, 221 (1999)). ¶ 30 “ ‘To have standing, *** the [claimant] must not be merely curious or concerned but must possess some personal claim, statu

2022App. 3d 1, 6 (2010) (quoting Glisson v. City of Marion, 188 Ill. 2d 211, 221 (1999)); see also Lynch v. Devine, 45 Ill.

2022App. 3d - 10 - No. 1-22-0793 1, 6 (2010) (quoting Glisson v. City of Marion, 188 Ill. 2d 211, 221 (1999)); see also Lynch v. Devine, 45 Ill.

2010Our supreme court has stated that “lack of standing in a civil case is an affirmative defense, which will be waived if not raised in a timely fashion in the trial court.” 7 1-09-2345 Greer v. Illinois Housing Development Authority, 122 Ill. 2d 462, 508 (1988); see also Lebron v. Gottlieb Memorial Hospital, 237 Ill. 2d 217, 252-53 (2010) (the defendant has the burden to plead and prove the affirmative defense of lack of standing, which will be forfeited if not timely raised in the trial court, and, under Illinois law, issues of standing do not implicate the court’s subject matter jurisdiction).

2010Our supreme court has stated that “lack of standing in a civil case is an affirmative defense, which will be waived if not raised in a timely fashion in the trial court.” Greer v. Illinois Housing Development Authority, 122 Ill. 2d 462, 508 (1988); see also Lebron v. Gottlieb Memorial Hospital, 237 Ill. 2d 217, 252-53 (2010) (the defendant has the burden to plead and prove the affirmative defense of lack of standing, which will be forfeited if not timely raised in the trial court, and, under Illinois law, issues of standing do not implicate the court’s subject matter jurisdiction).

2001App. 3d 459, 469 , 708 N.E.2d 508 (1999) ("In order to be granted an injunction, a plaintiff must have standing in the cause, which requires a showing of a clearly ascertainable right or interest that needs protection"); Glisson v. City of Marion , 188 Ill. 2d 211, 221 , 720 N.E.2d 1034 (1999) ("The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit").

2001App. 3d 459, 469 , 708 N.E.2d 508 (1999) (“In order to be granted an injunction, a plaintiff must have standing in the cause, which requires a showing of a clearly ascertainable right or interest that needs protection”); Glisson v. City of Marion, 188 Ill. 2d 211, 221 , 720 N.E.2d 1034 (1999) (“The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit”).

2024Reynolds v. Jimmy John’s Enterprises, LLC, 2013 IL App (4th) 120139, ¶ 33 (citing Jackson v. Randle, 2011 IL App (4th) 100790, ¶ 12 ). ¶ 22 “ ‘The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit,’ and ‘assures that issues are raised only by those parties with a real interest in the outcome of the controversy.’ ” Nationwide Advantage Mortgage Co. v. Ortiz, 2012 IL App (1st) 112755, ¶ 24 (quoting Glisson v. City of Marion, 188 Ill. 2d 211, 221 (1999)). “ ‘To have standing, *** the [claimant] must not be merely curious or concerned but

2018Reynolds, 2013 IL App (4th) 120139, ¶ 33 ; Jackson v. Randle, 2011 IL App (4th) 100790, ¶ 12 . “ ‘The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit,’ and ‘assures that issues are raised only by those parties with a real interest in the outcome of the controversy.’ ” Nationwide Advantage Mortgage Co. v. Ortiz, 2012 IL App (1st) 112755, ¶ 24 (quoting Glisson v. City of Marion, 188 Ill. 2d 211, 221 (1999)). ¶ 30 “ ‘To have standing, *** the [claimant] must not be merely curious or concerned but must possess some personal claim, statu

2021Further, plaintiff maintains it had physical possession of the original note, which was indorsed in blank and was produced in open court, and, therefore, the record establishes it had standing to foreclose. ¶ 88 “ ‘The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit.’ ” Deutsche Bank National Trust Co. v. Gilbert, 2012 IL App (2d) 120164, ¶ 15 (quoting Raintree Homes, Inc. v. Village of Long Grove, 209 Ill. 2d 248, 262 (2004)).

2016Deutsche Bank National Trust Co. v. Gilbert, 2012 IL App (2d) 120164, ¶ 15 .

2021In Illinois, “[t]he doctrine of standing is designed to preclude persons having no interest in a controversy from bringing suit, but it should not be an obstacle to the litigation of a valid claim.” People v. $1,124,905 U.S. Currency & One Chevrolet Astro Van, 177 Ill. 2d 314, 330 (1997).

2019In Illinois, "[t]he doctrine of standing is designed to preclude persons having no interest in a controversy from bringing suit, but it should not be an obstacle to the litigation of a valid claim." $ 1,124,905 U.S. Currency , 177 Ill. 2d at 330 , 226 Ill.Dec. 627 , 685 N.E.2d 1370 . ¶ 23 Importantly, under Illinois law, when a plaintiff alleges a statutory violation, no "additional requirements" are needed for standing.

2021Id. at 220-21 ; Lyons v. Ryan, 201 Ill. 2d 529, 534 (2002). ¶ 21 “The doctrine of standing is designed to preclude persons who have no interest in a controversy from bringing suit,” assuring that issues are raised only by parties with a “real interest in the outcome of the controversary.” Glisson, 188 Ill. 2d at 221 .

2019“Standing ensures that only those who have a real interest in the outcome are party to the case or controversy.” Id. ¶ 33 Parents have a fundamental liberty interest in raising their biological child, as well as a “superior right to the custody of their own children.” In re E.B., 231 Ill. 2d 459, 463-64 , 899 N.E.2d 218, 221 (2008); see also In re M.H., 196 Ill. 2d 356 , 362-63, 751 N.E.2d 1134 , 1140 (2001) (stating that both “the United States Supreme Court and Illinois courts recognize a parent’s fundamental right in the care, custody, and control of his or her children”).

2019“Standing ensures that only those who have a real interest in the outcome are party to the case or controversy.” Id. ¶ 33 Parents have a fundamental liberty interest in raising their biological child, as well as a “superior right to the custody of their own children.” In re E.B., 231 Ill. 2d 459, 463-64 , 899 N.E.2d 218, 221 (2008); see also In re M.H., 196 Ill. 2d 356 , 362-63, 751 N.E.2d 1134 , 1140 (2001) (stating that both “the United States Supreme Court and Illinois courts recognize a parent’s fundamental right in the care, custody, and control of his or her children”).

2019“Standing ensures that only those who have a real interest in the outcome are party to the case or controversy.” Id. ¶ 33 Parents have a fundamental liberty interest in raising their biological child, as well as a “superior right to the custody of their own children.” In re E.B., 231 Ill. 2d 459, 463-64 , 899 N.E.2d 218, 221 (2008); see also In re M.H., 196 Ill. 2d 356 , 362-63, 751 N.E.2d 1134 , 1140 (2001) (stating that both “the United States Supreme Court and Illinois courts recognize a parent’s fundamental right in the care, custody, and control of his or her children”).

2019“Standing ensures that only those who have a real interest in the outcome are party to the case or controversy.” Id. ¶ 33 Parents have a fundamental liberty interest in raising their biological child, as well as a “superior right to the custody of their own children.” In re E.B., 231 Ill. 2d 459, 463-64 , 899 N.E.2d 218, 221 (2008); see also In re M.H., 196 Ill. 2d 356 , 362-63, 751 N.E.2d 1134 , 1140 (2001) (stating that both “the United States Supreme Court and Illinois courts recognize a parent’s fundamental right in the care, custody, and control of his or her children”).