Justia Illinois Supreme Court Opinion Summaries

Tamica Rainey, a Chicago police officer, was injured in duty-related car accidents in 2013 and 2015. She was awarded duty disability benefits in 2017 based on injuries to her neck and shoulder. As required by statute, Rainey’s disability status was periodically reviewed, and in 2022, after multiple hearings and submissions of medical records, the Retirement Board of the Policemen’s Annuity and Benefit Fund of the City of Chicago discontinued her duty disability benefits, concluding she was no longer disabled from her duty-related injuries. However, when Rainey attempted to return to work, the police department determined she could not perform her duties.Rainey sought administrative review in the Circuit Court of Cook County, which reversed the Board’s decision, relying on precedent that an officer remains disabled if the department cannot provide a position with needed accommodations. The circuit court also awarded Rainey attorney fees and costs under section 5-228(b) of the Illinois Pension Code. The Board appealed, and the Appellate Court of Illinois, First District, affirmed both the restoration of Rainey’s benefits and the award of attorney fees and costs.The Supreme Court of Illinois reviewed the Board’s challenge to the attorney fees and costs award. The court held that section 5-228(b) of the Illinois Pension Code authorizes an award of attorney fees and costs not only to police officers who successfully challenge the initial denial of duty or occupational disease disability benefits, but also to those who successfully challenge the discontinuation of such benefits. The court rejected the Board’s argument that statutory attorney fee awards are limited to initial applications, finding the statute’s plain language and legislative intent favor such awards for both denial and discontinuation challenges. The Supreme Court affirmed the judgments of the appellate and circuit courts and reversed the Board’s decision. View "Rainey v. Retirement Board of the Policemen & Annuity and Benefit Fund of the City of Chicago" on Justia Law

Two police officers employed by a city were injured in separate incidents while on duty. After their injuries, both received payments from the city under section 1(b) of the Illinois Public Employee Disability Act, which provides that eligible employees unable to work due to a duty-related injury must continue to be paid “on the same basis” as before the injury, without deductions from sick leave, compensatory time, or vacation. The city continued to pay their salaries as before, including withholding federal and state income taxes, Social Security, and Medicare taxes. The officers filed suit, alleging that the city violated the Disability Act by withholding employment taxes and, for one officer, by deducting accrued leave time.The Circuit Court of Tazewell County granted summary judgment for the officers, finding that section 1(b) prohibited the withholding of employment taxes and required payment of “gross pay.” The court also found the city had improperly deducted leave time and held that the ten-year statute of limitations for breach of contract applied, awarding damages and fees to the plaintiffs. On appeal, the Illinois Appellate Court, Fourth District, reversed, holding that section 1(b) does not prohibit withholding employment taxes, and that the five-year statute of limitations applied. The appellate court also found a genuine issue of fact regarding whether leave time was improperly deducted and remanded for further proceedings.The Supreme Court of Illinois reviewed the case and affirmed the appellate court’s judgment. The court held that section 1(b) of the Disability Act does not prohibit a public employer from withholding employment taxes from payments made to an injured employee under that provision. The court reasoned that the statute’s language requires payment “on the same basis” as before the injury, which includes continued tax withholding, and expressly prohibits only certain deductions, not taxes. The case was remanded for further proceedings on the leave time deduction claim. View "Bitner v. City of Pekin" on Justia Law

A licensed clinical therapist and his employer provided substance abuse rehabilitation services to a physician whose medical license had been suspended. When the physician later sought reinstatement of his license, the Illinois Department of Financial and Professional Regulation requested the therapist’s personal notes from the rehabilitation program as part of the administrative proceedings. The therapist and his employer refused, asserting that the notes were protected under the Mental Health and Developmental Disabilities Confidentiality Act. They sought a protective order in the Circuit Court of Cook County to prevent disclosure of the notes.The circuit court conducted an in camera review and agreed that the notes were protected, issuing a protective order barring the Department from obtaining them. The court also awarded the plaintiffs attorney fees and costs under section 15 of the Confidentiality Act. The Department did not challenge the protective order but appealed the award of attorney fees and costs, arguing that such an award was barred by sovereign immunity. The Appellate Court of Illinois affirmed the circuit court’s award, holding that the fees and costs were ancillary to the injunctive relief and thus not barred by sovereign immunity.The Supreme Court of the State of Illinois reviewed the case to determine whether the circuit court had subject-matter jurisdiction to award attorney fees and costs against the Department. The court held that, absent an explicit statutory waiver of sovereign immunity, Illinois courts lack jurisdiction to enter monetary judgments against the State for attorney fees and costs. The court found that section 15 of the Confidentiality Act does not contain such a waiver. Therefore, the Supreme Court reversed the appellate court’s judgment and the portion of the circuit court’s judgment awarding attorney fees and costs, but did not disturb the protective order itself. View "Lavery v. Department of Financial and Professional Regulation" on Justia Law

Plaintiffs, a class of individuals, filed mortgage foreclosure complaints in Illinois circuit courts and paid "add-on" filing fees mandated by section 15-1504.1 of the Code of Civil Procedure. They challenged the constitutionality of these fees, asserting that the statute violated the free access clause of the Illinois Constitution. The Illinois Supreme Court previously agreed, declaring the statute unconstitutional and affirming an injunction against its enforcement.The Will County circuit court initially certified the class and granted partial summary judgment, finding the statute unconstitutional. The appellate court reversed, and the case was remanded. On remand, plaintiffs pursued a refund of the fees. The circuit court dismissed the refund claim, citing sovereign immunity, which bars claims against the State. The appellate court reversed, holding that the circuit court had jurisdiction under the officer-suit exception to sovereign immunity, which allows suits against state officials for unconstitutional actions.The Illinois Supreme Court reviewed the case and held that while the officer-suit exception allowed the circuit court to enjoin the enforcement of the unconstitutional statute, it did not apply to the refund claim. The court determined that the refund claim was a retrospective monetary award to redress a past wrong, which falls under the jurisdiction of the Court of Claims, not the circuit court. Consequently, the Illinois Supreme Court reversed the appellate court's judgment and affirmed the circuit court's dismissal of the refund claim. View "Walker v. Chasteen" on Justia Law

Habdab, LLC filed a complaint for declaratory judgment in the circuit court of Lake County against the County of Lake and the Village of Mundelein, seeking to invalidate certain fees imposed under an intergovernmental agreement (IGA). Habdab claimed the fees violated the Road Improvement Impact Fee Law (Impact Fee Law) and sought to avoid paying unconstitutional road improvement impact fees. Both parties filed cross-motions for summary judgment. The circuit court denied Habdab's motion and granted summary judgment in favor of the County. The appellate court affirmed the circuit court's decision.The appellate court held that the fees imposed under the IGA did not constitute "road improvement impact fees" under the Impact Fee Law because they were not conditioned on the issuance of a building permit or a certificate of occupancy. The court also found that the doctrine of unconstitutional conditions did not apply, as there was an essential nexus and rough proportionality between the fees and the legitimate state interest of preventing traffic congestion.The Supreme Court of Illinois reviewed the case and affirmed the appellate court's judgment. The court held that the IGA fees did not fall under the definition of "road improvement impact fees" as per the Impact Fee Law, which specifically applies to fees imposed as a condition to the issuance of a building permit or certificate of occupancy. The court also agreed that the unconstitutional conditions doctrine did not apply, as there was a legitimate state interest in minimizing traffic congestion and a rough proportionality between the fees and the impact of the proposed development. View "Habdab, LLC v. County of Lake" on Justia Law

Marathon Petroleum Company LP (Marathon) was audited by the Cook County Department of Revenue (Department) for gasoline and diesel transactions between January 2006 and July 2014. The Department determined that Marathon failed to collect and remit taxes on certain transactions, specifically "book transfers," and assessed taxes, interest, and penalties. Marathon argued that these transactions were financial settlements of forward contracts, not taxable sales, and sought administrative review.An administrative law judge (ALJ) upheld the Department's assessments, finding that Marathon did not provide sufficient documentary evidence to prove that the book transfers did not involve a change of ownership or movement of fuel. Marathon then sought judicial review, and the circuit court reversed the ALJ's decision, finding that the Department's assessments were unreasonable and that Marathon had provided sufficient evidence to rebut the Department's prima facie case.The appellate court reversed the circuit court's decision, affirming in part the ALJ's decision and remanding for a recalculation of the amount due. The appellate court held that the Department's auditing method was reasonable and that Marathon did not meet its burden of rebutting the Department's prima facie case. The appellate court also found that the transfer of an intangible ownership interest was enough to make the book out transactions taxable.The Supreme Court of Illinois reviewed the case and found that the ALJ misunderstood some of the evidence presented by Marathon. The court held that Marathon provided sufficient documentary evidence to rebut the Department's prima facie case and that the ALJ's conclusion was clearly erroneous. The court reversed the appellate court's judgment, affirmed in part and reversed in part the circuit court's judgment, and remanded the case to the Cook County Department of Administrative Hearings for further proceedings to determine if the Department can prove its case of taxability under the Fuel Tax Ordinance. View "Marathon Petroleum Co. LP v. Cook County Department of Revenue" on Justia Law

The case involves a wrongful-death lawsuit filed by the executors and an independent administrator of the estates of deceased residents of a nursing home, Geneva Nursing and Rehabilitation Center, LLC, doing business as Bria Health Services of Geneva. The plaintiffs allege that Bria negligently and willfully failed to control the spread of COVID-19, leading to the deaths of the decedents between March and May 2020. The complaints assert that Bria's failure to quarantine symptomatic staff and residents and to implement effective hygiene and equipment procedures caused the decedents to contract COVID-19 and die from related complications.The Kane County Circuit Court denied Bria's motions to dismiss the negligence claims but allowed Bria to file a motion to certify a question for interlocutory appeal. The certified question was whether Executive Order 2020-19 provided blanket immunity for ordinary negligence to healthcare facilities that rendered assistance to the State during the COVID-19 pandemic. The appellate court modified the question to clarify that the immunity in question derived from section 21(c) of the Illinois Emergency Management Agency Act and answered the modified question affirmatively, stating that Bria would have immunity from negligence claims if it could show it was rendering assistance to the State during the pandemic.The Supreme Court of Illinois reviewed the case and agreed with the appellate court's modification of the certified question. The court held that Executive Order 2020-19, which triggered the immunity provided in section 21(c) of the Act, grants immunity for ordinary negligence claims to healthcare facilities that rendered assistance to the State during the COVID-19 pandemic. The court affirmed the appellate court's judgment and remanded the case to the circuit court to determine whether Bria was indeed rendering such assistance. View "James v. Geneva Nursing & Rehabilitation Center, LLC" on Justia Law

The case revolves around a dispute between Shawnee Community Unit School District No. 84 (the School District) and Grand Tower Energy Center, LLC (Grand Tower), the owner of a power plant in Jackson County, Illinois. For the 2014 tax year, the Jackson County assessor imposed an assessed value of $33,445,837 on Grand Tower’s property. Grand Tower appealed the assessment to the Jackson County Board of Review, which reduced the assessed value of the property to $31,538,245. Grand Tower then appealed to the Property Tax Appeal Board (PTAB) under section 16-160 of the Property Tax Code, seeking a further reduction of the final assessment imposed by the board of review. The School District, which receives funding from property taxes generated in that county, was granted leave to intervene in the appeal.While the appeal was pending before the PTAB, Grand Tower’s 2014 property taxes came due. Grand Tower did not pay the taxes. In December 2015, the Jackson County collector prepared the annual list of properties with delinquent taxes, which included Grand Tower’s property. The collector then applied to the circuit court of Jackson County for a judgment and order of sale for taxes on the 2014 delinquent properties, including Grand Tower’s. The court entered a judgment and order of sale.The School District filed a motion before the PTAB seeking dismissal of Grand Tower’s appeal, arguing that Grand Tower was required to pay the 2014 property taxes under protest in order to pursue an appeal before the PTAB. The School District also argued that once the Jackson County collector made the application for judgment and order of sale, the circuit court acquired jurisdiction over the taxes and all supplemental matters, including the determination of the assessment, thereby divesting the PTAB of jurisdiction to review the 2014 assessment. The PTAB denied the School District’s motion to dismiss.The School District appealed the PTAB’s decision to the appellate court, which affirmed the decision of the PTAB. The appellate court held that payment of the contested taxes was not a condition precedent to pursuing an appeal before the PTAB and that the tax sale proceedings in the circuit court did not divest the PTAB of jurisdiction to review the 2014 and 2015 property assessments.The School District then appealed to the Supreme Court of the State of Illinois. The Supreme Court affirmed the judgment of the appellate court, holding that the payment of disputed property taxes is not a condition precedent to pursuing an appeal before the PTAB under section 16-160 of the Code, and that the county collector’s application for judgment and order of sale did not divest the PTAB of its jurisdiction to review Grand Tower’s properly filed appeals. The court also held that the entry of the judgment and order of sale did not estop Grand Tower from seeking review of its 2014 and 2015 assessments before the PTAB. View "Shawnee Community Unit School District No. 84 v. Illinois Property Tax Appeal Board" on Justia Law

The case involves the City of Joliet and five commercial truck drivers who were fined for violating city ordinances prohibiting overweight and/or overlength vehicles on nondesignated highways. The drivers challenged the city's jurisdiction to administratively adjudicate the ordinance violations, arguing they were entitled to have the violations dismissed because applicable law required that they be adjudicated in the circuit court. The hearing officer overruled the drivers' objections and denied their motions to dismiss. The drivers then filed a complaint for administrative review in the circuit court of Will County, which affirmed the decisions of the hearing officer.The appellate court reversed the decisions of the circuit court and hearing officer, following a previous First District's opinion which held that home rule municipalities are prohibited from administratively adjudicating "traffic regulations governing the movement of vehicles," in addition to "reportable offense[s] under Section 6-204 of the Illinois Vehicle Code." The City of Joliet appealed this decision to the Supreme Court of Illinois.The Supreme Court of Illinois found that section 1-2.1-2 of the Illinois Municipal Code does not preempt the City of Joliet's home rule authority to administratively adjudicate violations of its ordinances. Therefore, it vacated that part of the appellate court's judgment. However, the court also found that the hearing officer's administrative decisions were precluded by the Joliet Code of Ordinances, and thus affirmed, on different grounds, that part of the appellate court's judgment that reversed the judgment of the circuit court and the administrative decisions of the City. The court concluded that the administrative decisions were reversed, and the circuit court judgment was reversed. View "Cammacho v. City of Joliet" on Justia Law

This case involves a dispute between a grain producer, Robert Miller, and the Illinois Department of Agriculture over compensation from the Illinois Grain Insurance Fund. The fund is intended to compensate grain producers for losses incurred when a licensed grain dealer or a licensed warehouseman fails. Miller made a claim with the Department after his grain dealer, SGI Agri-Marketing, LLC, failed before making payment under a “price later contract.”A key issue in the case was the interpretation of the Grain Code's provision concerning the pricing of grain under a “price later contract.” According to the Code, if such a contract is not signed by all parties within 30 days of the last date of delivery of grain intended to be sold by the contract, then the grain is automatically priced on the next business day after those 30 days, at the market price of the grain at the close of that day.Miller argued that the grain was priced when he signed a purchase confirmation, which was within the 160-day window before the failure of the dealer, thus entitling him to compensation from the fund. The Department contended that the Grain Code automatically priced the grain as a matter of law on the next business day after 30 days from the last grain delivery, as the parties had not signed a contract agreeing to a pricing formula by then.The Supreme Court of the State of Illinois agreed with the Department’s interpretation. It held that the statute was unambiguous and provided that the grain would be priced as a matter of law on the next business day after 30 days from the last delivery. Therefore, because the grain was priced outside the 160-day protection window prescribed by the Grain Code, Miller was not eligible for compensation from the fund. The Supreme Court affirmed the circuit court’s judgment and reversed the appellate court's judgment. View "Miller v. Department of Agriculture" on Justia Law