Glens of Hanover Condominium Association v. Carbide, 6 N.E.3d 856

Glens of Hanover Condominium Association filed a 2010 forcible entry and detainer action seeking possession of Unit 1624-2 and related charges.
After failed service attempts, plaintiff obtained alternative service and secured a default judgment including attorney fees.
Defendant moved to quash service and vacate the default; appellate court reversed and vacated the default judgment in Carbide I, without remanding.
Following reversal, defendant filed a turnover motion for possession, rents, and attorneys’ fees; plaintiff sought to set the case for trial.
Trial court ruled it lacked jurisdiction to entertain turnover or set for trial because there was no remand; defendant appealed.
Issue presented: whether, after reversal without remand, the trial court revests with jurisdiction over ministerial matters.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had jurisdiction after reversal without remand.	Glens contends defendant’s turnover filing submits to trial court jurisdiction.	Carbide asserts the trial court retains jurisdiction to entertain motions following reversal.	No jurisdiction revestment after reversal without remand.

Watkins v. Dunbar, 318 Ill. 174 (Illinois, 1925) (reversal without remand does not revest jurisdiction; enforcement possible only with remand)
Dalan/Jupiter, Inc. v. Draper & Kramer, Inc., 372 Ill. App. 3d 362 (Illinois Appellate, 2007) (reversal without remand does not revest trial court with jurisdiction)
Brandon v. Caisse, 172 Ill. App. 3d 841 (Illinois Appellate, 1988) (concerns lack of remand and effect on jurisdiction to award fees)
McNeil v. Ketchens, 2011 IL App (4th) 110253 (Illinois Appellate (4th Dist.), 2011) (partially affirms and reverses can revest jurisdiction; here reversal without remand did not revest)
Berger v. Matthews, 216 Ill. App. 3d 942 (Illinois Appellate, 1991) (collateral fee issues do not affect appealability of the judgment)