Law Offices of William J. Stogsdill v. Cragin Federal Bank for Savings

Plaintiff, the Law Offices of William J. Stogsdill, P.C., sued defendant, Cragin Federal Bank for Savings (the bank), for losses incurred when the bank allegedly paid unauthorized checks drawn by plaintiff’s bookkeeper for her own use. Plaintiff’s fifth amended complaint included count III, which alleged that the bank violated the Consumer Fraud and Deceptive Business Practices Act (the Act) (815 ILCS 505/1 et seq. (West 1992)). The trial court dismissed count III for failure to state a cause of action. Plaintiff appeals, contending that the court erred in implicitly finding that the Act does…