A village police officer towed a vehicle that had five parking citations. The following day, an individual went to the police department and offered to pay $22 to the village, which he claimed satisfied the debt, and demanded the car be returned. The village refused to release the vehicle. Subsequently, the individual filed a lawsuit against the village alleging unjust enrichment on the village’s part in keeping the vehicle, among other claims. The circuit court dismissed the lawsuit, finding that the individual had no standing to sue the village because he was not the owner of the vehicle and had no legal interest to sue the village for its return.
On appeal, the Illinois Appellate Court agreed that he had no standing to sue the village. The individual had conceded he was not the owner of the vehicle, and the court found that his voluntary $22 payment towards the debt of another did not establish sufficient a “legal interest” to satisfy the standing requirements for his lawsuit. Bey v. Village of Midlothian, et al.
