Palmer v. Mellen
Illinois Court of Appeals
74 N.E.3d 1034 (2017)
A family land trust and partnership formed in 1977 faced dissolution when most of the 26 partners, led by Martha Palmer (plaintiff), sought to sell the land after the partnership couldn't afford to buy out members wanting to exit; the Mellens (defendants), one of whom served as a manager requiring unanimous consent for certain decisions, objected to the sale and allegedly became verbally and physically intimidating toward other partners while refusing to attend meetings or communicate about partnership business. The trial court granted summary judgment dissolving the partnership, and the Mellens appealed.
Whether a court may dissolve a partnership if a partner's conduct makes it not reasonably practicable to carry on the business in partnership with that partner, or otherwise not reasonably practicable to carry on the business consistent with the partnership agreement.