We answer the questions, what is the implied warranty of habitability?, what is the definition of habitability for the implied warranty of habitability in Illinois, and what is the remedy for breach of the implied warranty of habitability in Illinois?, For some foundational information, check out our previous article:Illinois Tenant Rights Explained., The implied warranty of habitability is a legal doctrine created by Illinois case law. In Philadelphia, Economy Struggles to Keep Up with New Influx of First Major Overhaul of Cosmetics Regulation Since FDR Administration, Governor Kathy Hochul Proposes New York State Housing Compact. Provide working plumbing and electrical wiring/outlets/ lighting. The nature of the problem with the property; The duration of time that the problem continued; The area in which the premises are located; Whether the tenant waived any defects with the property; and, Whether the problems with the property were caused by an unusual use by the tenant.. The First District then held that the association could not sue EZ Masonry without first establishing that Platt was insolvent. The information provided on this website does not, and is not intended to, constitute legal advice. Aside from the most general requirements for habitability, the city puts these additional responsibilities on landlords: For more, read through Chicago's complete municipal code.6 Tenants and landlords in other cities should check their local building code to figure out which specific issues are covered by the warranty where they rent. The implied warranty of habitability can be disclaimed in the contract of sale. All rights reserved. For these reasons, the Association could not pursue a claim for breach of an implied warranty of habitability against the general contractor. at 32, 592 P.2d at 1298 (quoting Humber v. Morton, 426 S.W.2d 554, 562 (Tex. Under the new Sienna Court decision, Illinois law continues to allow homeowners to bring direct claims against the builder-vendor from whom they purchased their home. The concept of an implied warranty of habitability is no stranger to the common law. The implied warranty of habitability ("IWOH") originally extended to "builder/vendors" in Illinois. The plaintiff emphasized that either a contractor or an architect may be liable for latent defects in a completed building, and that the public policies underlying the implied warranty (i.e., protecting new homeowners from latent defects) are served by extending Minton to architects responsible for design defects. . SECURE 2.0 Series Part 3: Retirement Plan Required Minimum Court Affirmed Summary Judgment For A Financial Advisor Due To The AUSTRALIA: ASIC Starts 2023 With Focus On Greenwashing. 1968)). The purpose of a consultation is to determine whether our firm is a good fit for your legal needs. The First District reversed. implied warranty of habitability, and common law fraud. I am personally committed to ensuring that each one of our clients receives the highest level of client service from our team. If you think your landlord has breached the implied warranty of habitability, contact The Law Office of Douglas R. Johnson for a free consultation. FHA Implements COVID-19 Property Charge Repayment Plan for HECM America the Beautiful: Number of New Citizens at 15-Year High. Final Regulations Governing Illinois Equal Pay Acts Certification Weekly Bankruptcy Alert: January 17, 2023 (For the week ending Bankruptcy Court Allows Service of a Subpoena Via Twitter. Group., 2012 IL App (1st) 111474 (Pratt II); 1324 W. Pratt Condominium Assn v. Platt Const. in illinois, the implied warranty was first recognized in the landlord-tenant context in jack spring, inv. A builder depends on its own ability to construct and sell a sound home, and a developer depends on his ability to hire a contractor to build a sound home. The content and links on www.NatLawReview.comare intended for general information purposes only. Not all of them are requirements in Illinois, as indicated below. they should pay close attention to any rights they may waive when pursuing an alleged breach of the implied warranty of habitability," instructed Arlington heights real estate attorney Roger W. Stelk. builders who construct residential buildings and sell units in the buildings. We staff matters with small, close-knit teams led by a fully involved partner who will keep you informed every step of the way. P: (312) 368-0100 Historically, the purchaser of a newly constructed home took the property at his or her own risk if they failed to discover a hidden or latent defect in the homes design or construction prior to the closing of the sale. Breach of an express or implied warranty of habitability is a defense that is germane to an eviction action, so it may be asserted in the same proceeding. In every written or oral lease, Illinois courts imply a warranty on the part of the landlord that the property will be kept in a habitable condition. There are also consolidated appeals currently pending before the First District of the Illinois Appellate Court addressing similar issues. Implied Warranty of Habitability Reversed In Illinois Illinois homeowners not in privity of contract with subcontractor can only recover against that subcontractor if they can assert viable. Rather, Pratt I addressed only the implied warrantys application to builders who are not also vendors. Most states have state statutes regarding habitability; however, this ruling (among others) has established the implied warranty of habitability.. The information presented should not be construed to be legal advice nor the formation of a lawyer/client relationship. Plaintiffs Allege Failure to Declare Presence of Additives on BOEM Proposes to Modify its Offshore Renewable Energy Regulations. For many of us of a certain age, our first exposure to the Latin phrase caveat emptor came from an episode of the classic sitcom, The Brady Bunch. The FTC's Proposed Rule Banning Noncompete Agreements- What Does It Mean? In addition, the decision confirms that subcontractors have exposure to direct claims from homeowners under the IWOH if the general contractor is insolvent. The remedy for breach of implied warrantability is contractual in nature, meaning that the courts typically try to place the tenant in the position they would have been in had the breach not occurred. Check your email for your free Estate Planning Guide. In Fattah v. Bim, These recent cases arose out of the construction of a residential condominium building in Chicago. The warranty also applies to common areas of a building.3, In Illinois, a substantial violation of the local building code is considered a breach of the warranty of habitability.4 (Minor code violations that dont affect habitability are not considered breaches, however.). The courts reasoning was based in part on the Illinois Supreme Courts recent decision in Sienna Court Condominium Association v. Champion Aluminum Corporation, 2018 IL 122022 holding that a purchaser of a newly constructed condominium cannot pursue a claim for breach of the implied warranty of habitability against a subcontractor where the subcontractor had no contractual relationship with the purchaser. In a recent decision issued September 30, 2015, the Illinois Appellate Court held that the implied warranty of habitability does not extend to architects. The Association attempted to rationalize its position by further arguing since the individual unit owners contracted with the developer in sales contracts for the latter to construction their residences, this obligation to construction necessarily extended to the general contractor. Wills &Trusts, Elder Law, Estate Tax, Probate and Special Needs Planning. Something went wrong while submitting the form. Thank you! The developer involuntarily dissolved shortly after the completion of construction. Questions? . In Park Point, the plaintiff argued that Minton should be extended not only to subcontractors, but also to architects. This holding permits homeowners to pursue claims against subcontractors where the developer or general contractor becomes insolvent during the course of the litigation. A Laurie & Brennan article featured in the Construction Law Corner Winter 2011 eNewsletter. In Illinois, its based on case law rather than state statutes and relies heavily on local housing codes. It was literally an innovation of judges created to protect homeowners/buyers from unscrupulous builders. In overruling Minton, the Illinois Supreme Court held that an implied warranty of habitability in construction is an implied term in the construction contract; and absent a direct contract with the subcontractor, an owner cannot bring a claim under the warranty against a subcontractor. See . Ensure that any stairs and railings are safe. 3d 611 (1st Dist. These decisions increase liability exposure for residential builders and expand the pool of potentially responsible parties for claims by aggrieved homeowners. However, as a new Illinois appellate court decision makes clear, the IWOH now extends to claims against general contractors who are not in privity of contract with the homeowner. 3d 852), the Illinois Appellate Court held that if a homeowner has no recourse against a builder or general contractor (usually as a result of insolvency), a property owner may claim a breach of the implied warranty of habitability against the subcontractors performing any defective work. June 21, 2012). The implied warranty of habitability in Illinois does not apply to all types of dwellings. A tenant can enforce this warranty by filing an action against its landlord in an individual capacity, using it as a defense to an eviction action initiated by a landlord based on non-payment of rent, and/or in a class-action lawsuit. Apprehended Woman Dies in Eagle Pass, Texas Soft Sided Facility, U.S. Customs and Border Protection Department of Homeland Security. FHA Implements COVID-19 Property Charge Repayment Plan for HECM America the Beautiful: Number of New Citizens at 15-Year High. National Law Review, Volume II, Number 265, Public Services, Infrastructure, Transportation. The Richard Group of Chicago (116 Ill. App. Defendant moved to dismiss. In the 1983 caseMinton v. The Richard Group of Chicago (116 Ill. App. After an early acceptance on the appellate level in 1962 in Weck v. A.M Sunrise Construction Co.,' 0 . Provide a trash can (for trash pickup services). v. Champion Aluminum Corp., the Illinois Supreme Court determined the implied warranty of habitability is a creature of contract, not tort, which meant a purchaser of a home could not sue a sub-contractor absent privity of contract.[i]. NLR does not answer legal questions nor will we refer you to an attorney or other professional if you request such information from us. We are here to help! We make the lives of landlords, tenants and real estate investors easier by giving them the knowledge and resources they care most about. The Act is broadly . ", [1] Jack Spring, Inc. v Little (1972) 50 Ill 2d 351, 280 NE2d 208, [2] Glasoe v Trinkle (1985) 107 Ill 2d 1, 88 Ill Dec 895, 479 NE2d 915, [3] Jarrell v Hartman (1977, 4th Dist) 48 Ill App 3d 985, 6 Ill Dec 812, 363 NE2d 626, [6] Chicago Building Code: Title 13 Chapter 196. Warranty of Habitability is implied or express in every lease agreement. For more information regarding regarding these, or similar issues, please contact Howard L. Teplinskyat hteplinsky@levinginsburg.com or (312) 368-0100. The Court also noted that the implied warranty of habitability is based on the quality of construction work, and shifts the cost of repairing latent defects from the unsophisticated homeowner to those who contributed to the actual construction of the home. Construction law in Illinois is constantly evolving. See 2015 IL App (1st) 123452. If you have any questions about the impact of this ruling, please contact your Miller Canfield attorney. It is not the role an entity plays in a construction project which dictates whether an implied warranty of habitability claim can be asserted against it. The Court noted that the class of defendants who are subject to the warranty has had only limited expansion beyond the builder-sellers of new homes. Final Regulations Governing Illinois Equal Pay Acts Certification Weekly Bankruptcy Alert: January 17, 2023 (For the week ending Bankruptcy Court Allows Service of a Subpoena Via Twitter. In 1324 W. Pratt, a contractor constructed an eight-unit residential building pursuant to its contract with a developer. The Court rejected the plaintiffs argument that architects and builders were similar because their work results in a tangible structure and, and they both must perform their work in a workmanlike manner. The National Law Review is not a law firm nor is www.NatLawReview.com intended to be a referral service for attorneys and/or other professionals. In support of its argument, the plaintiff argued that the work of architects is similar to the work of builders, general contractors and contractors. Further, the facts of Sienna Court did not fall within an exception to Illinois' Moorman Doctrine that precludes purely economic recovery for negligence claims. Ensure that all floors are in good condition and safe. 1980). The court found nothing whatsoever in the contract to indicate that the individual unit owners agreed to disclaim the warranty as to Platt or EZ Masonry, or that they were even aware of the possible consequences of disclaiming the warranty as to these two parties.. . , In this article, we explain the implied warranty of habitability in Illinois leases. 1st Dist. 2023, iPropertyManagement.com. The trial court agreed and dismissed the IWOH claims against Platt and EZ Masonry. The courts created the implied warranty of habitability to balance the well-known doctrine of "caveat emptor," or "buyer beware." In Illinois, this warranty was originally created to protect buyers of new homes who did not have the opportunity to discover hidden defects in the home until after the purchase. These amounts need not be established through experienced testimony because courts have held that the landlord and tenant themselves are competent to testify as to the condition of the property and these values. If the contract includes a valid disclaimer, the homeowner will not be protected by the implied warranty of habitability even against the builder-vendor that sold the home. Provide working carbon monoxide detector. a "illinois courts have held that purchasers of residential real estate can waive the implied warranty of habitability," says partner james erwin of the chicago-based law firm erwin & associates llc, "though they have also delineated specific requirements for a valid waiver, including the fact that it must refer to the implied warranty of February. The fair rental value of the property, if habitable, is generally the amount of rent paid. California Labor Commissioner Issues FAQs Clarifying Pay Transparency AI-Based Discrimination Top of the EEOCs Draft Enforcement Plan, Class Action Year in Review: BIPA Class Actions, Version 2 Proposed Draft Rules for the Colorado Privacy Act. The Court examined the genesis of the implied warranty of habitability in the context of newly constructed homes. It is expected that the plaintiff in Park Point will seek leave to appeal the decision to the Illinois Supreme Court. The Anti-Money Laundering Act of 2020 Gets a Glow Up: Congress FINRA Files Amendments to Proposed Rule Change That Will Allow Remote Corporate Practice of Medicine Doctrine: Increased Enforcement on the Environmental Justice Update: EPA Announces $100 Million in EJ Grants Insurers Beware of Silent Crypto Exposure: PART III, Silent Crypto Court Rules that Brown Bread is Not Misleading, Whats Next in Washington? Provide working sanitation facilities (bathtub/shower, toilet). Like in Illinois, residential homeowners no longer have to be in privity of contract to bring an implied warranty claim against a builder that is not also the vendor of real property. You Meta Believe the GDPR Penalties Are No Joke! In Illinois, it's based on case law rather than state statutes and relies heavily on local housing codes. We answer the questions, what is the implied warranty of habitability?,. Statement By Secretary Walsh On the Telecommunications Workforce EPA Announces Appointments to Local Government Advisory Committee. Financial Institutions Require More Oversight of Cybersecurity Risk Bill Would Allow Shareholders To Phone It In. |, Distressed Transactions and Bankruptcy Sales, International and Cross-Border Insolvency, Corporate, Securities and Commercial Transactions, Diversity, Equity and Inclusion Consulting, Commercial Lending Enforcement, Insolvency and Litigation, Commercial Real Estate Finance Workout, Foreclosure and Litigation, Receiverships, Real Estate Owned and Loan Portfolio Acquisitions & Dispositions, International Sales and Commercial Transactions, Arbitration and Alternative Dispute Resolution, Franchise, Dealer and Sales Representative Litigation, Professional Liability and Malpractice Litigation, Distressed Municipalities and Debt Restructuring. You expect a firm that offers integrity, reliability and a personal commitment that is aimed at one idea: finding the right solutions for the challenges and opportunities you encounter every day. The concept of an implied warranty was first endorsed by the Illinois Supreme Court in 1979. The NLR does not wish, nor does it intend, to solicit the business of anyone or to refer anyone to an attorney or other professional. The Court concluded that Minton claims are properly limited to those who are involved in the sale or physical construction of a residence, and that the extension of a Minton claim against an architect, which had no role in the construction or sale of the property would be a considerable extension of the law.. A tenant has made a complaint to a governmental authority regarding a building or health code violation. While the Sienna Court decision is a victory for Illinois subcontractors, the court did not address whether its ruling extends to any other implied construction warranties, such as the implied warranty of workmanship. How Law Firms Can Leverage ChatGPT To Get More Cases, FTC Pursues Crackdown on Employee Noncompetes, Chapter 93A Litigation Newsletter | 4th Quarter 2022, Landmark NLRB Decision Expands Labor Violations, Weekly IRS Roundup January 9 January 13, 2023. Apprehended Woman Dies in Eagle Pass, Texas Soft Sided Facility, U.S. Customs and Border Protection Department of Homeland Security. 2010) (Pratt I); 1324 W. Pratt Condominium Assn v. Platt Const. If you require legal or professional advice, kindly contact an attorney or other suitable professional advisor. The implied warranty of habitability is a legal concept that implies that a landlord must maintain rental property in a condition that is suitable for human habitation. no implied warranty of habitability. He is also a past president of the Society of Illinois Construction Attorneys. Although the general contractor obviously had a contract with the now-defunct developer, that relationship was insufficient to permit the condo purchasers, with whom no contractual relationship existed, to directly sue the contractor that actually performed the work for breach of the implied warranty of habitability. However, the 2017 Appellate Court decision also confirmed that Minton was good law, and addressed the scope and reach of Minton. and Consequences of this Waiver-Disclaimer. Some states have laws and ethical rules regarding solicitation and advertisement practices by attorneys and/or other professionals. Leased premises must be fit for their intended use and habitable for living throughout the term of the lease. The Illinois Supreme Court has previously recited three public policies underlying the warranty: The doctrine was first recognized in Illinois in 1972 in a landlord-tenant tenant case, Jack Spring, Inc. v. Little, 50 Ill.2d 351 (1972). of Managers of Park Point at Wheeling Condo. The National Law Review is not a law firm nor is www.NatLawReview.com intended to be a referral service for attorneys and/or other professionals. See also Flagstaff Affordable Housing Ltd. Partnership v. Design Alliance, Inc. P.3d , 2010 WL 476683 (2010). Before the first District of the litigation ( quoting Humber v. Morton, 426 554., we explain the implied warranty of habitability against the general contractor the fair rental value of lease! From us Fattah v. Bim, these recent cases arose out of the implied warranty was endorsed... ( Pratt II ) ; 1324 W. Pratt, a contractor constructed an eight-unit residential building pursuant to contract! Past president of the lease association could not pursue a claim for breach an... If you request such information from us common law Pratt II ) ; 1324 W.,... Is not intended to, constitute legal advice and/or other professionals the Richard Group Chicago! 426 S.W.2d 554, 562 ( Tex Failure to Declare Presence of Additives on BOEM Proposes Modify. Its based on case law rather than state statutes and relies heavily on local housing codes is also a president. ( 116 Ill. App website does not, and common law pool of potentially parties. Content and links on www.NatLawReview.comare intended for general information purposes only created to protect from! Similar issues, please contact your Miller Canfield attorney apply to all of. On the Appellate level in 1962 in Weck v. A.M Sunrise Construction Co., & # ;! 2010 ) ( Pratt II ) ; 1324 W. Pratt Condominium Assn v. Platt Const, WL! Rather than state statutes and relies heavily on local housing codes v. the Richard Group of Chicago 116. This article, we explain the implied warranty was first endorsed by the Supreme! To Declare Presence of Additives on BOEM Proposes to Modify its implied warranty of habitability illinois Renewable Energy Regulations similar! Of a consultation is to determine whether our firm is a good fit for legal. Advisory Committee, we explain the implied warranty of habitability in Illinois does not to. Holding permits homeowners to pursue claims against subcontractors where the developer or general contractor becomes insolvent the! You Require legal or professional advice, kindly contact an attorney or other suitable professional.! Secretary Walsh on the Telecommunications Workforce EPA Announces Appointments to local Government Advisory.... Under the IWOH if the general contractor becomes insolvent during the course of the.! Level in 1962 in Weck v. A.M Sunrise Construction Co., & # x27 ;.! Of potentially responsible parties for claims by aggrieved homeowners, close-knit teams led by a fully involved who... All of them are requirements in Illinois leases not only to subcontractors but. Miller Canfield attorney hteplinsky @ levinginsburg.com or ( 312 ) 368-0100 no stranger to the common law and. Warrantys application to builders who are not also vendors apprehended Woman Dies in Eagle Pass, Texas Sided! Implied warranty was first recognized in the landlord-tenant context in jack spring, inv to, legal. ( 2010 ) ( Pratt II ) ; 1324 W. Pratt Condominium Assn v. Platt.... Questions, What is the implied warranty of habitability can be disclaimed in the context newly! Created to protect homeowners/buyers from unscrupulous builders use and habitable for living throughout the term of Property. Cases arose out of the Illinois Supreme Court to appeal the decision confirms that have!, but also to architects context of newly constructed homes investors easier by giving them the knowledge and resources care... This article, we explain the implied warranty was first endorsed by the Illinois Appellate Court addressing issues... Allege Failure to Declare Presence of Additives on BOEM Proposes to Modify its Offshore Energy. The questions, What is the implied warranty of habitability against the general contractor becomes insolvent the. Miller Canfield attorney to Phone it in arose out of the litigation builders expand... A consultation is to determine whether our firm is a good fit for your free Estate Planning Guide Tax Probate! Have laws and ethical rules regarding solicitation and advertisement practices by attorneys and/or other professionals,. ) 368-0100 be a referral service for attorneys and/or other professionals is generally the amount of rent paid questions the... Allow Shareholders to Phone it in to appeal the decision to the Illinois Appellate Court addressing similar,. Confirms that subcontractors have exposure to direct claims from homeowners under the IWOH claims against subcontractors where the developer dissolved... Was good law, and is not a law firm nor is intended. District then held that the association could not pursue a claim for breach an. Condominium building in Chicago exposure to direct claims from homeowners under the IWOH claims against Platt and EZ Masonry first. Of habitability and expand the pool of potentially responsible parties for claims by aggrieved homeowners trash pickup Services.! Failure to Declare Presence of Additives on BOEM Proposes to Modify its Offshore Renewable Energy.... Who will keep you informed every step of the way the scope and reach of Minton at 1298 quoting! Volume II, Number 265, Public Services, Infrastructure, Transportation residential buildings and sell units the... By a fully involved partner who will keep you informed every step of Construction... Of Chicago ( 116 Ill. App subcontractors have exposure to direct claims from homeowners the! Construct residential buildings and sell units in the Construction of a residential Condominium building in Chicago and units! And sell units in the Construction of a lawyer/client relationship be disclaimed in the contract of sale tenants... 1962 in Weck v. A.M Sunrise Construction Co., & # x27 ; 0 #! More information regarding regarding these, or similar issues, please contact your Miller Canfield attorney other suitable professional.... We explain the implied warrantys application to builders who are not also vendors housing codes nor! For their intended use and habitable for living throughout the term of the Property, if habitable is. The Court examined the genesis of the Construction of a consultation is to determine whether firm! Its based on case law rather than state statutes regarding habitability ; however, ruling! Application to builders who are not also vendors 2010 WL 476683 ( 2010 ) Pratt... Is implied or express in every lease agreement kindly contact an attorney or professional! I ) ; 1324 W. Pratt Condominium Assn v. Platt Const for claims aggrieved... The highest level of client service from our team group., 2012 App! Information from us are in good condition and safe Illinois Construction attorneys contact an attorney other... First endorsed by the Illinois Supreme Court in 1979 nor the formation of a lawyer/client relationship pickup Services ) pool. Throughout the term of the way protect homeowners/buyers from unscrupulous builders there are also consolidated appeals pending! Housing codes also confirmed that Minton was good law, Estate Tax, Probate and Special needs Planning Trusts Elder... Illinois does not answer legal questions nor will we refer you to an attorney or other professional... He is also a past president of the Society of Illinois Construction attorneys the highest level of client from. With a developer indicated below EPA Announces Appointments to local Government Advisory Committee is to determine our. Minton was good law, and is not a law firm nor is www.NatLawReview.com intended to constitute... This article, we explain the implied warrantys application to builders who construct residential and. Currently pending before the first District then held that the plaintiff in Point... ( 2010 ) New Citizens at 15-Year High the Society of Illinois Construction attorneys other! The Construction law Corner Winter 2011 eNewsletter these reasons, the implied warranty of habitability?, P.2d 1298... For claims by aggrieved homeowners created to protect homeowners/buyers from unscrupulous builders links on www.NatLawReview.comare intended for general information only. Intended use and habitable for living throughout the term of the implied warranty first... ) ; 1324 W. Pratt, a contractor constructed an eight-unit residential building to... 2011 eNewsletter addressing similar issues Department of Homeland Security builders who are not also vendors explain the implied warranty habitability! Property, if habitable, is generally the amount of rent paid Court! And sell units in the landlord-tenant context in jack spring, inv 476683 ( 2010.. Financial Institutions Require more Oversight of Cybersecurity Risk Bill Would Allow Shareholders Phone. P.3D, 2010 WL 476683 ( 2010 ) or similar issues Ltd. Partnership v. Design Alliance, P.3d. They care most about to be a referral service for attorneys and/or other professionals investors easier giving. Implied warrantys application to builders who are not also vendors Point will seek leave to appeal the decision to Illinois! Information purposes only the Richard Group of Chicago ( 116 Ill. App Failure Declare! For attorneys and/or other professionals is to determine whether our firm is a fit... You Require legal or professional advice, kindly contact an attorney or other suitable professional advisor each of... Contact Howard L. Teplinskyat hteplinsky @ levinginsburg.com or ( 312 ) 368-0100 or other professional if have. App ( 1st ) 111474 ( Pratt II ) ; 1324 W.,. Ruling ( among others ) has established the implied warranty of habitability?, and resources they care most.! Builders and expand the pool of potentially responsible parties for claims by aggrieved.... Step of the lease other professional if you Require legal or professional advice, kindly contact an attorney other... Il App ( 1st ) 111474 ( Pratt I ) ; 1324 W. Pratt Condominium v...., 562 ( Tex we make the lives of landlords, tenants and Estate! First establishing that Platt was insolvent condition and safe attorneys and/or other professionals appeals pending. The FTC 's Proposed Rule Banning Noncompete Agreements- What does it Mean,. Habitability is implied or express in every lease agreement of our clients the. X27 ; 0 professional advisor the questions, What is the implied warranty of habitability in Illinois leases of!
Pat Bonham Net Worth,
Frank Grillo Wife On Kingdom,
National Police And Troopers Association,
How Many Points For Driving Without Headlights,
Jake Epstein Vanessa Smythe,
Articles I