ILCS » Chapter 765 · Act 77
Illinois Compiled Statutes

765 ILCS 77/45 (2026)

Other law

✓ current as of May 2026
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(765 ILCS 77/45)
    Sec. 45. Other law. This Act is not intended to limit remedies or modify any obligation to disclose created by any other statute or that may exist in common law in order to avoid fraud, misrepresentation, or deceit in the transaction.
(Source: P.A. 102-765, eff. 5-13-22.)

    
Notes of Decisions
Cited in 12 cases, 2000–2018 · leading case: Penn v. Gerig, 778 N.E.2d 325 (Ill. App. Ct. 2002).
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Penn v. Gerig, 778 N.E.2d 325 (Ill. App. Ct. 2002). “” 765 ILCS 77/45 (West 1996). Therefore, because an aggrieved home buyer has remedies available in addition to those created by the Act, a strict application of the one-year limitations period set forth in the Act does not lead to the “harsh results” that initially prompted…”
Rolando v. Pence, 769 N.E.2d 1108 (Ill. App. Ct. 2002). “” 765 ILCS 77/45 (West 1998). However, they argue that, because the Act does not create any obligations to disclose beyond what is set forth in the Act, it is insufficient to characterize what is essentially a qualified representation made under the Act as independently…”
The Henderson Square Condo. Ass'n v. Lab Townhouses, 2014 IL App (1st) 130764 (Ill. App. Ct. 2014). “" 765 ILCS 77/45 (West 2010). ¶ 114 Plaintiffs cite to various cases interpreting the Disclosure Act to argue how we should interpret section 13-72-030 of the Chicago Municipal Code.”
King v. Ashbrook, 732 N.E.2d 621 (Ill. App. Ct. 2000). “See 765 ILCS 77/45 (West 1998); Hirsch v. Feuer, 299 Ill.”
Anderson v. KLASEK, 913 N.E.2d 615 (Ill. App. Ct. 2009). “” However, the Disclosure Act is certainly more than a codification of common law fraud because section 45 of the Disclosure Act specifically states, “This Act is not intended to limit or modify any obligation to disclose created by any other statute or that may exist in common…”
Blevins v. Marcheschi, 2018 IL App (2d) 170340 (Ill. App. Ct. 2018). “See 765 ILCS 77/45 (West 2014). ¶ 24 In sum, the Disclosure Act does not limit plaintiffs' ability to bring claims *813 based on the common law or other statutes, and plaintiffs can rely on the disclosures made pursuant to the Disclosure Act to seek recovery on such theories.”
Blevins v. Marcheschi, 2018 IL App (2d) 170340 (Ill. App. Ct. 2018). “See 765 ILCS 77/45 (West 2014). ¶ 24 In sum, the Disclosure Act does not limit plaintiffs’ ability to bring claims based on the common law or other statutes, and plaintiffs can rely on the disclosures made pursuant to the Disclosure Act to seek recovery on such theories.”
Henderson Square Condo. Ass' v. LAB Townhomes, L.L.C., 2014 IL App (1st) 130764 (Ill. App. Ct. 2014). “Section 45 of the Disclosure Act states that it is not “intended to limit or modify any obligation to disclose created by any other statute or that may exist in common law in order to avoid fraud, misrepresentation, or deceit in the transaction.”
The Henderson Square Condo. Ass'n v. LAB Homes, L.L.C., 2014 IL App (1st) 130764 (Ill. App. Ct. 2014). “" 765 ILCS 77/45 (West 2010). ¶ 116 Plaintiffs cite to various cases to argue how we should interpret section 13-72-030 of the Chicago Municipal Code.”
The Henderson Square Condo. Ass'n v. Lab Townhouses, 2014 IL App (1st) 130764 (Ill. App. Ct. 2014). “" 765 ILCS 77/45 (West 2010). ¶ 115 Plaintiffs cite to various cases interpreting the Disclosure Act to argue how we should interpret section 13-72-030 of the Chicago Municipal Code.”
Penn v. Gerig (Ill. App. Ct. 2002). “" 765 ILCS 77/45 (West 1996). Therefore, because an aggrieved home buyer has remedies available in addition to those created by the Act, a strict application of the one-year limitations period set forth in the Act does not lead to the "harsh results" that initially prompted…”
King v. Ashbrook (Ill. App. Ct. 2000). “See 765 ILCS 77/45 (West 1998); Hirsch v. Feuer , 299 Ill.”
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