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Lappin v. Gerard
No. 3-94-0388 (Ill. App. Ct. May 31, 1995) ; Clearinghouse Number: 50759
Description
Judgment Debt Agreed to by Debtor Before Learning That His Income Is Exempt from Attachment Is Vacated
Abstract
The Illinois Appellate Court has held that because defendant
debtor’s income is exempt from attachment he cannot be
required to make payments toward a judgment owed to plaintiff
creditor. Plaintiff had filed a complaint against defendant for
forcible entry and detainer and past-due rent. The parties,
appearing pro se, stipulated to a judgment granting plaintiff
possession, $1,200, and costs. Defendant was ordered to pay $100
per month toward the judgment. Defendant did not make the payments,
and a rule to show cause was entered against him. Defendant secured
counsel and filed a motion to vacate the earlier order and to quash
the rule to show cause. Defendant asserted that his only income
came from social security and veterans benefits, which under state
law are exempt from judgment and attachment for rent. The court
denied these motions, found the agreed order to be enforceable, and
found defendant in civil contempt and ordered him to pay $150 in
attorney fees. Defendant appealed. The appellate court held that
although plaintiff’s money judgment is valid, the order
requiring defendant to pay $100 per month is not because
defendant’s income is exempt from attachment. In addition,
the court reversed the order of contempt because the underlying
order on which it was based was invalid.
