In Jackson v. Reeter, 201 Ill. App. 29 (1915), the appellee had filed suit against the appellant to recover from the appellant for the use and occupation of certain farm lands. The trial court entered judgment in favor of appellee, and on appeal, the appellate court reversed. Jackson, 201 Ill. App. 29. The appellate court explained, "At the common law, rents or compensation for use and occupation could not be recovered except where the relation of landlord and tenant was shown to exist," Jackson, 201 Ill. App. at 31. The court stated, "The only statutory enactment that changes this common-law rule is section 1 of Chapter 80, Rev. St. (J & a P 7039), which provides: "That the owner of lands, his executors or administrators may sue for and recover rent therefor, or a fair and reasonable satisfaction for the use and occupation thereof, by action of debt or assumpsit, in any court of competent jurisdiction, in any of the following cases:' then follows a list of five conditions upon which such recovery may be had." Jackson, 201 Ill. App. at 31. The court noted that when one party occupies the premises of another without any agreement for the payment of rent, "the law implies a promise on the part of the occupant to pay the owner, for the use and occupation thereof, a reasonable rental value." Jackson, 201 Ill. App. at 32. The court explained that to be entitled to recover upon the theory of an implied promise to pay reasonable compensation, "one must be the owner of some estate in the premises and the possession of the other must not be under claim of title or adverse to that of the owner or under an agreement that he need not pay rent." Jackson, 201 Ill. App. at 32. The court found that "appellee was not the owner of the land occupied by appellant, or of any estate in it while he was in possession. Nor did he recognize appellee as having any right, title or interest in it. He held it adversely to appellee." Jackson, 201 Ill. App. at 32.