The appellate court affirmed with one justice specially concurring and one justice dissenting. 378 Ill. App. 3d 676. We granted the taxpayers' petition for leave to appeal. 210 Ill. 2d R. 315. For the reasons that follow, we reverse the judgments of the appellate and circuit courts and remand the cause to the circuit court for further proceedings consistent with this opinion.
Apportionment of sheriff's sale proceeds and statutory interpretation are questions of law that this court reviews de novo. Acme Markets, Inc. v. Callanan, 378 Ill. App. 3d 676, 677-78, 882 N.E.2d 181, 182 (2008). In claiming that their liens have priority over LaSalle's mortgage, Edon and Eagle misread the requirements set forth in section 16 of the Act.
No. 106198.May 2008 378 Ill. App. 3d 676. Disposition of Petitions for Leave to Appeal Allowed.
PTELL is also commonly known by the name of its predecessor, the Tax Cap Act. See Acme Markets, Inc. v. Callanan, 378 Ill. App. 3d 676, 679 (2008). --------
"The purpose of [the] PTELL 'is to provide citizens greater control over the levy of taxes they are required to pay.' " Acme Markets, Inc. v. Callanan, 236 Ill. 2d 29, 42 (2009) (quoting Acme Markets, Inc. v. Callanan, 378 Ill. App. 3d 676, 684 (2008) (McDade, P.J., dissenting)). In general, taxing districts subject to the PTELL cannot extend taxes at a rate that exceeds the "extension limitation" without referendum approval.
¶ 14 A. Standard of Review¶ 15 This decision involves statutory interpretations of the Attorneys Lien Act and the Mechanics Lien Act. Statutory interpretations are questions of law that this court reviews de novo. Acme Markets, Inc. v. Callanan, 378 Ill.App.3d 676, 677–78, 317 Ill.Dec. 607, 882 N.E.2d 181 (2008). The parties are correctly in agreement that the standard of review to be employed in this action is de novo review.
¶ 14 A. Standard of Review ¶ 15 This decision involves statutory interpretations of the Attorneys Lien Act and the Mechanics Lien Act. Statutory interpretations are questions of law that this court reviews de novo. Acme Markets, Inc. v. Callanan, 378 Ill. App. 3d 676, 677-78 (2008). The parties are correctly in agreement that the standard of review to be employed in this action is de novo review.