Brockett Ex Rel. Brockett v. Davis

JUSTICE HOLDRIDGE,

dissenting:

I respectfully dissent. I would affirm the trial court. The majority’s finding that Davis lacked standing to challenge the validity of the bills issued by Dr. Childs and ODR ignores the fact that, in the underlying lawsuit, the plaintiffs sought to hold Davis liable for those bills. Clearly, Davis was in immediate danger of sustaining a direct injury (i.e., liability for payment of certain bills), and potential injury to his property rights was far more than abstract. I would find that Davis had standing to challenge the validity of the bills that plaintiffs sought to require him to pay.

Likewise, on the merits, I would affirm the trial court. An unlicensed entity cannot collect for services it rendered that would require a license. Tovar v. Paxton Community Memorial Hospital, 29 Ill. App. 3d 218, 220 (1975). Likewise, where the licensing requirements are promulgated for the protection of the public, our courts have held that contracts violating statutes governing the licensing of professionals injure the public welfare and therefore cannot be enforced under any theory, including quantum meruit. See Ransburg v. Haase, 224 Ill. App. 3d 681, 684-85 (1992). As there was no factual dispute over the appellants’ failure to comply with the licensing provisions of the Medical Corporation Act (805 ILCS 15/5 et seq. (West 1998)), I would find that the trial court was correct in granting defendant’s motion for summary judgment.