Lake County Grading Co. v. Village of Antioch, 2014 IL 115805

Lake County Grading sues Village of Antioch for breach of contract related to public works bonds for Neumann Homes.
Village contracted with Neumann to install public improvements in NeuHaven and Clublands subdivisions.
Neumann issued four Fidelity bonds totaling $18,128,827, none expressly guaranteeing payment to subcontractors.
Lake County Grading supplied labor and materials; Neumann defaulted and later declared bankruptcy; notices of lien were served Feb 18, 2008.
Trial court awarded summary judgment for Lake County Grading on breach counts II and IV; appellate court reversed; Illinois Supreme Court reverses appellate and circuit judgments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Bond Act §1 deeming require payment provisions in bonds lacking explicit language?	Lake County Grading contends deeming clause makes bonds include payment.	Village argues deemed provisions render bonds compliant with payment obligations.	Yes; bonds are deemed to contain payment and completion provisions.
Do 180-day limitations apply to breach claims when no explicit payment bond was procured?	Lake County Grading argues limitations do not bar breach claims.	Village contends 180-day limit applies to bond-related actions.	Court declines to resolve beyond deeming conclusion; remand for summary judgment on counts II and IV.

Carroll Seating Co. v. Verdico, 369 Ill. App. 3d 724 (2006) (protects subcontractors under Bond Act context)
Aluma Systems, Inc. v. Frederick Quinn Corp., 206 Ill. App. 3d 828 (1990) (construction bond interpretations)
Housing Authority v. Holtzman, 120 Ill. App. 2d 226 (1970) (public works bond purpose and protections)
Ardon Electric Co. v. Winterset Construction, Inc., 354 Ill. App. 3d 28 (2004) (discusses bonds and payment obligations)
Fodge v. Board of Education of the Village of Oak Park, District 97, 309 Ill. App. 109 (1941) (early Bond Act interpretation)