Delarosa v. APPROVED AUTO SALES, TNC.

Plaintiff, Juan Delarosa, filed a two-count complaint against defendant, Approved Auto Sales, Inc., alleging a violation of the Consumer Fraud and Deceptive Business Practices Act (815 ILCS 505/1 et seq. (West 2000)) and common-law fraud. After an arbitration proceeding, plaintiff moved to amend the complaint to add a third count for breach of contract, and the trial court denied the motion. Following a bench trial, the court entered directed findings for defendant on the two fraud counts. The court then sua sponte reversed its earlier ruling on the proposed amendment, filed the complaint as…