The Illinois Appellate Court recently issued a ruling in the case of Michelmann Steel Construction Co. v. Link Media Midwest, LLC (Docket No. 4-25-1262), which addresses critical issues surrounding lease agreements and property rights. The court's decision affects both companies involved and sets important precedents for future lease disputes.

In this case, Michelmann Steel Construction Company (Michelmann) sued Link Media Midwest, LLC (Link Media) over the removal of billboard structures from a property in Quincy, Illinois. The court's ruling clarifies the rights of landlords and tenants regarding the removal of personal property after a lease has ended, as well as the measures of damages in conversion claims.

Background

Michelmann, an Illinois corporation, owned a lot on 24th Street in Quincy, where it had leased space for billboard advertising to various companies over the years. The dispute arose when Link Media, which had become the assignee of a previous lessee, Outdoor Graphics, Inc., removed the billboard structures from the property on April 19, 2019.

Michelmann claimed that Link Media's actions constituted conversion, tortious interference with business relationships, and breach of contract. The case was brought before the Adams County circuit court, where a bench trial was held based solely on documentary evidence. The circuit court ruled in favor of Michelmann on the breach of contract claim but sided with Link Media on the conversion and tortious interference claims.

The Ruling

The Illinois Appellate Court reviewed the case and issued its judgment on October 26, 2026. The court found that unless a lease agreement provides a tenant with a reasonable time to remove personal property after termination, the tenant must remove such property while still in possession of the premises. The court noted, "Unless the lease agreement provides the tenant a reasonable time after termination of the lease for removal of trade fixtures and other personal property of the tenant, the tenant must remove such personal property while the tenant is in possession of the premises."

Regarding the conversion claim, the court ruled that although Michelmann proved conversion, it failed to demonstrate the fair market value of the converted property. As a result, Michelmann was entitled only to nominal damages. The court stated, "Absent a demonstration by citation to relevant authorities that the replacement value of the property, as opposed to its fair market value, is a valid measure of damages for conversion, plaintiff failed to prove the damages resulting from the conversion and, consequently, was entitled to only nominal damages for the conversion."

The court also addressed the tortious interference claim, stating that Michelmann had forfeited this issue due to a lack of reasoned argument supported by relevant authorities. Ultimately, the court affirmed the circuit court's judgment in part, reversed it in part, and remanded the case with directions to enter judgment in favor of Michelmann for nominal damages for conversion.

Impact

This ruling has significant implications for landlords and tenants regarding lease agreements. It clarifies that tenants must remove their personal property while still in possession of the leased premises unless the lease specifies otherwise. This aspect of the ruling emphasizes the importance of clear lease terms and the responsibilities of tenants regarding their property.

Additionally, the court's decision regarding the measure of damages in conversion claims highlights the necessity for plaintiffs to establish the fair market value of converted property to recover more than nominal damages. This aspect of the ruling could influence future cases involving property disputes and conversion claims.

What's Next

Link Media may seek to appeal the ruling, but details regarding any potential appeal were not available in the court filing. As of now, there are no related cases pending that directly involve the same parties.