MD Electrical Contractors, Inc. v. Abrams

Plaintiff, MD Electrical Contractors, Inc., sued defendants, Fred and Carol Abrams, in quantum meruit to recover for improvements that it made as a subcontractor on a home improvement project. Defendants moved to dismiss the complaint (see 735 ILCS 5/2— 619(a)(9) (West 2004)), contending that, because plaintiff had violated the Home Repair and Remodeling Act (Act) (815 ILCS 513/1 et seq. (West 2004)), it could not recover. The trial court granted the motion. On appeal, plaintiff contends that (1) the Act does not apply to plaintiff as a subcontractor, and (2) even if the Act does apply, it…