Tri-Plex Technical Services, Ltd. v. Jon-Don, LLC

Summary

The Illinois Supreme Court reversed the appellate court and affirmed dismissal of Tri-Plex’s complaint. It held that the Deceptive Trade Practices Act claims were barred because Tri-Plex had not first exhausted the required administrative remedy before the Pollution Control Board, and that the Consumer Fraud Act claims failed because Tri-Plex did not allege that it was the intended recipient of the defendants’ alleged deception or that the deception proximately caused its injury. The court also held that the civil conspiracy claim failed because it depended on the dismissed statutory claims.