Justia Illinois Supreme Court Opinion Summaries

Citizens, unhappy with how public education is funded in Illinois, sought a declaratory judgment, alleging that the funding system requires taxpayers in school districts with low property values to pay property taxes to fund local public schools at a higher rate than similarly situated taxpayers in school districts with higher property values, in violation of the equal protection clause of the Illinois Constitution. The circuit court dismissed; the appellate court affirmed. The Illinois Supreme Court held that the complaint was properly dismissed for lack of standing. The funding statute is not a taxing statute; plaintiffs failed to establish that the inequalities alleged are a direct result of the enforcement of the education funding statute or are fairly traceable to defendants’ actions. It is entirely within the discretion of the school districts to determine the actual rate of local property taxes, and the funding statute does not require school districts to tax at a certain rate. Although a district might decide that more local property tax revenues are required in order to provide students with a sufficient education, that decision is left to the school district and is not compelled or required by the educational funding statute. View "Carr v. Koch" on Justia Law

Plaintiffs were sexually abused by their teacher, White, at an Urbana school. Before working in Urbana, White was a teacher in the McLean County school district. Plaintiffs filed suit against White, Urbana, individual administrators, the McLean County district, and individual McLean administrators. Plaintiffs alleged that between 2002 and 2005, McLean administrators acquired actual knowledge of White’s teacher-on-student sexual harassment, sexual abuse, or sexual “grooming” of minor female students, but never recorded these incidents in White’s personnel file or employment record, failed to make timely mandated reports of abuse by White, and failed to investigate parental complaints. According to the complaint McLean disciplined White for “sexual harassment, sexual grooming, and/or sexual abuse” of minor female students, then entered into a severance agreement with White which concealed his sexual abuse of students and created a falsely positive letter of reference for White. The trial court dismissed with respect to the McLean defendants, finding they owed no duty. The appellate and supreme courts ruled in favor of plaintiffs. The state sovereign immunity law does not extend to conduct that is willful or wanton, 745 ILCS 10/2-202; the alleged fact are sufficient to establish that, having undertaken the affirmative act of filling out White’s employment verification form,defendants had a duty to use reasonable care in ensuring that the information was accurate. View "Jane Doe-3 v. McLean Cnty. Unit Dist. No. 5 Bd. of Dirs." on Justia Law

In summer 2010, due to budget deficits, the board laid off 1,289 teachers. Laid-off teachers were not given preference for positions available in the district, nor were all vacancies posted on the website. In August, 2010, there was an increase in funding. Approximately 715 tenured teachers were recalled, but many positions were filled with new hires, rather than laid-off tenured teachers. There was no official recall policy. The Seventh Circuit certified, to the Supreme Court of Illinois, the question of whether the School Code (105 ILCS 5/34-18(31)), provides that Chicago tenured teachers have a right to be rehired after an economic layoff and whether they have a right to certain procedures during rehiring. The court responded that Chicago public schools are treated differently under the School Code. In all the other districts, laid-off tenured teachers have a right of recall and, subject to certification and seniority, have a right to be rehired into new vacancies in their districts for a specific period. Under 1995 amendments Chicago teachers were not given those rights. The supreme court declined to read into School Code language something which the legislature did not put there. View "Chicago Teachers Union v. Bd. of Educ., City of Chicago" on Justia Law

Defendant, a school district, leased portable classrooms from plaintiff under contracts including penalties for early cancellation or default. Under the Downstate School Finance Authority for Elementary Districts Law (105 ILCS 5/1F-1) the state later created the Authority to manage the District's finances. The Authority canceled the leases before expiration, but did not authorize payment of the cancellation fees. The trial court granted summary judgment, finding it was legally impossible for the District to pay the cancellation fees, but also finding that the Authority had to comply with the cancellation terms of the leasing contracts. The appellate court affirmed the judgment in favor of the District on the cancellation fees and vacated as moot the declaratory judgment in favor of plaintiff. The Illinois Supreme Court concluded that the legislature intended the Act to permit the Authority to cancel a school district's contract with a third party, but that cancellation must be consistent with the contractual terms agreed to by the school district and the third party. The Authority can cancel the leasing contracts, but must pay the contractual fees for early cancellation. View "Innovative Modular Solutions v. Hazel Crest Sch. Dist. 152.5" on Justia Law

The regional board of school trustees dissolved a school district, partially located in Montgomery County, and annexed it to a district previously located entirely in Sangamon County. About 99.7 percent of the reconstituted district is in Sangamon County and the voters of that county had approved a referendum under the Property Tax Extension Limitation Law (PTELL)(35 ILCS 200/18â185); the voters in Montgomery County had not. A taxing district subject to PTELL may not ordinarily extend taxes at a rate that exceeds the previous yearâs extension by more than 5%, or the percentage increase in the Consumer Price Index, whichever is less, without referendum approval. The district, wanting to issue bonds to finance improvements, sought a declaration that PTELL did not apply. Reversing the trial and appellate courts, the supreme court held that the entire district remains subject to the PTELL.