Trial Court Sanctions Ruling Too Terse. Appellate Court Sends It Back For More Specificity

Lake Environmental was doing asbestos removal at Scott Air Force Base in southern Illinois. The State, claiming that Lake had violated regulations, persuaded the Department of Public Health to revoke Lake’s asbestos removal license. Lake asked the trial court to review the department’s decision. But while that review was still pending, the State filed another complaint in the Department that asked for penalties and an injunction.

The trial court reversed the Department’s decision to revoke the license. Lake then asked the court to sanction the State. The trial court¬†denied the sanction request, but did not say why. So Lake appealed the denial of sanctions to the Illinois Fifth District Court of Appeals.

The appellate court ruled that it had no basis to affirm the denial of sanctions¬†because the trial court’s terse denial did not meet the requirement that a court must provide a reasoned analysis for its sanctions ruling.

This is how the court explained it:

“A reviewing court should not be put in the position of making the trial court’s findings” and “should not be required to speculate as to which of the determinitive facts and legal theories the trial court relied on in deciding” whether to allow or deny sanctions.

The appellate court reversed the no-sanctions decision and sent the case back to the trial court with directions to issue an opinion stating “with specificity” why it denied sanctions.

Click here to read the entire opinion, Lake Environmental v. Arnold, 2014 IL App (5th) 130109 (7/10/2014).