Palos Cmty. Hosp. v. Humana, Inc.

1 Citing case

  1. Mitchell/Roberts P'ship v. Williamson Energy, LLC

    2020 Ill. App. 5th 190339 (Ill. App. Ct. 2020)   Cited 2 times

    ¶ 79 We next consider an amendment to Pierce Deed A, which further confirms the intent of the parties and supports our conclusion. Although the plaintiffs contend that the Pierce Amendment is parol evidence and may not be considered, Illinois law establishes that an instrument is to be interpreted as a whole, and when amendments are made, courts consider all parts of the agreement to determine the intent of the parties. Palos Community Hospital v. Humana, Inc. , 2020 IL App (1st) 190633, ¶ 34, ––– Ill.Dec. ––––, ––– N.E.3d –––– ; see also Downers Grove Associates v. Red Robin International, Inc. , 151 Ill. App. 3d 310, 318, 104 Ill.Dec. 393, 502 N.E.2d 1053 (1986) (where agreement is modified by separate agreement, both instruments are read together to determine parties' rights and obligations). ¶ 80 Pierce Deed A was recorded on March 15, 1913.