Municipal Minute

Another AI Hallucination Case

2026-03-31T10:51:00.003-05:00

Although today's case summary isn't related to local government issues, it is an important reminder to be careful in relying on AI (artificial intelligence) for legal work, particularly in filings with the court.

In Dec v. Markwayne Mullin, the Seventh Circuit Court of Appeals addressed a challenge by a Polish citizen who was denied a waiver of the waiting period for a family-based visa that requires a person to leave the country and remain abroad for ten years. The Department of Homeland Security (DHS) denied her waiver request and she sued. The district court dismissed her lawsuit, holding that the applicable federal law precludes judicial review of agency decisions on waiver requests. She then appealed to the Seventh Circuit Court of Appeals, which upheld the dismissal of her case.

In addition to upholding the dismissal of her case, the Seventh Circuit also addressed deficiencies in the appellate brief filed on her behalf by her attorney. The Court noted that her brief cited two cases that do not exist and included an imaginary quotation, which the Court noted had "tell-tale signs of AI hallucinations" (although the plaintiff's attorney argued she did not use AI in her brief). The Court acknowledged that courts have been grappling with the use of generative AI in briefs filed with the court, particularly when it produces AI hallucinations and non-existent case citations. The Court expressed its concerns, particularly that trained lawyers are failing to check the accuracy of legal citations and quotations in their filings with the court. The Court was not only concerned about the plaintiffs' counsel inclusion of these hallucinated cases, but also the fact that opposing counsel in the case (DHS attorneys) failed to catch these errors and bring them to the attention of the court.

The Court's discussion is a reminder to all lawyers and parties to litigation that they exercise caution in their use of AI in drafting briefs filed with the court and to double-check their legal arguments and any supporting citations. That cautionary reminder is not restricted to the attorneys filing with the court, but also to opposing counsel who fail to catch these errors.

Reminder of Updated Web Accessibility Requirements

2026-03-26T08:30:00.001-05:00

In April 2024, the Department of Justice issued a final rule updating Title II of the Americans with Disabilities Act (ADA) regulations to ensure that state and local governments’ web content is accessible to persons with disabilities.

Under the new rule, local governments must ensure their websites and mobile applications meet the technical standards of the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. An ADA fact sheet on the rule is available here.

The deadline to comply with the rule depends on the population reported for the local government in the 2020 U.S. Census Bureau data:

State and local government size	Compliance date
0 to 49,999 persons	April 26, 2027
Special district governments	April 26, 2027
50,000 or more persons	April 24, 2026

Local governments should reach out to their legal counsel if they have questions about compliance with these new regulations.

Post Authored by Katie Nagy, Ancel Glink

GSMCON Conference Schedule Released

2026-03-25T08:55:00.000-05:00

For all my government communicator/social media coordinator readers, the Government Social Media Conference (GSMCON) has released its full schedule for this year's annual conference which will take place May 4 - 7, 2026 in New Orleans and will offer both in-person and virtual attendance options. You can find the full schedule here. Note that if you are planning to register for in-person attendance, there are a limited number of those tickets remaining.

If you are going to be at this year's conference, don't miss the two sessions Julie Tappendorf will be presenting (info below):

Thursday, May 7th - 9:00 a.m. - 9:30 a.m.

What Counts as Protected Speech on Social Media?

Julie Tappendorf, Ancel Glink, PC

We’ll cover what types of comments have First Amendment protection and how those protections apply to your agency’s social media pages. This Speed Session focuses on the core constitutional principles that guide everyday moderation decisions, helping you understand how protected speech plays out in common social-media scenarios.

Thursday, May 7th - 10:15 a,m. – 10:45 a.m.

AI-Generated Content Risks

Julie Tappendorf, Ancel Glink, PC

This Speed Session highlights the emerging legal risks of artificial intelligence in government social media workflows. We’ll look at how AI may raise questions related to copyright protections for creative content and the considerations social media content creators and moderators should keep in mind. You’ll leave with a clearer understanding of key legal issues to be aware of when using AI tools.

In the Zone: Appellate Court Addresses Annexation Challenge in Solar Farm Case

2026-03-23T08:30:00.002-05:00

A company leased property in unincorporated Kane County intending to develop a solar farm. After the company applied for a special use permit from the county, the city council approved a resolution protesting the application and representatives of the city, as well as others, objected to the application at the county ZBA hearing on the application. Ultimately, the county board approved the special use permit, and shortly thereafter, the city adopted an ordinance to forcibly annex the subject property and adjacent parcels. The annexation ordinance stated that the property was "wholly bounded" by the city based on a previous voluntary annexation of railroad property.

The company filed a lawsuit against the City (in quo warranto) claiming that the annexations did not satisfy certain statutory requirements. First, the company argued that the annexation territory was not "wholly bounded" as required by section 7-1-13 of the Illinois Municipal Code because the adjacent ComEd property did not qualify as a "public utility right of way" to satisfy the contiguity exception under the annexation statute. Second, the company argued that the voluntary annexation of the railroad property was a "sham transaction" solely intended to meet the "wholly bounded" requirement of the annexation statute.

The circuit court dismissed the case, finding no deficiencies in either the forcible annexation of the annexation property or the previous voluntary annexation of the railroad property.

The company appealed, and the Appellate Court issued a ruling in RPIL Solar 10, LLC v. City of Aurora, agreeing with the circuit court that the challenge to the voluntary annexation of the railroad property as a "sham" was properly dismissed. However, the Appellate Court overturned the circuit court's dismissal of the company's challenge to the forcible annexation. The Court noted that in order for a municipality to forcibly annex property under section 7-1-13, the property must be "wholly bounded" by one or more municipalities and/or a forest preserve district. The Court acknowledged there were certain exceptions in the statute, including property that is separated from a city by a public utility right of way, which is what the city relied on in annexing the annexation property. The company responded that because ComEd owned the disputed property in "fee simple," it did not qualify as a public "right of way" under the limited exception. The Appellate Court agreed, finding that a fee simple interest is not the same as a right of way interest under the annexation statute. As a result, the Court held that the company did adequately allege a quo warranto claim to challenge the forcible annexation, and that claim should not have been dismissed by the circuit court. The case was sent back to the circuit court for further proceedings.

In the Zone: Court Rejects Challenge to Zoning Approval for Dispensary

2026-03-17T11:14:00.005-05:00

An Illinois Appellate Court upheld the dismissal of a neighbor objector lawsuit challenging a city's zoning approval of a marijuana dispensary. Neighbors Against a Marijuana Dispensary v. Chicago Zoning Board of Appeals, et al.

MariGrow applied for a special use permit from a city zoning board of appeals to establish an adult use cannabis dispensary in the city. A sign was posted on the property indicating the application had been filed, and notice of a community meeting was published in the newspaper. The applicant also mailed notice of the community meeting to property owners within 250 feet of the property, and the alderman for the ward in which the property was located sent an e-newsletter to all ward residents informing them of the community meeting. More than a hundred people attended the community meeting.

Two months after the community meeting, the ZBA held a public hearing on the special use application. A representative for an objector group requested a 60 day continuance of the hearing to prepare a formal case against the application, which was denied by the ZBA chair. At the hearing, both the applicant and representatives of the objector group testified about the application for a special use permit. After the application was approved by the ZBA, the objector group filed an administrative review action against the ZBA and applicant, arguing that its due process rights had been violated when the ZBA denied its request for a continuance and granted the special use permit. The circuit court ruled in favor of the ZBA, finding that the objector group was not denied due process and had not established that it had standing to pursue the administrative review action.

On appeal, the Appellate Court upheld the ruling in favor of the ZBA.

First, the Appellate Court held that the objector group failed to identify any members owning property within 250 feet of the proposed dispensary, either at the zoning hearing or in its complaint, and its general assertion in the complaint that the group had members who owned property within 250 feet was insufficient to demonstrate standing under section 11-13-7 of the Zoning Enabling Act.

As to the due process claim, the Court found that notice of the zoning hearing complied with all statutory requirements and that the objector group did, in fact, have (and exercised) its right to be heard at the hearing. The Court rejected the objector group's argument that the ZBA should have granted its request for a continuance to give it more time to prepare its objections, finding that representatives of the objector group had been involved in the previous community meeting two months before the hearing, and that any failure to adequately prepare was not due to lack of notice or insufficient time.

In short, the Appellate Court determined that the ZBA did not violate the objector group's rights when it approved the special use application.

Appellate Court Sends FOIA Case Back to Circuit Court

2026-03-12T08:47:00.005-05:00

In Dorman v. Madison County Board, an Illinois Appellate Court determined that the circuit court made an error in dismissing a FOIA challenge and sent the case back for further proceedings.

An individual filed two separate FOIA requests for various records, including records relating to allegations of employee misconduct and communications regarding an election. The individual subsequently filed a lawsuit against the public bodies involved, claiming they violated FOIA regarding both requests. The public bodies responded that they had provided records in response to most of the requests but regarding records not produced, the public bodies asked the circuit court to allow them to rely on the unduly burdensome provision of FOIA as the responsive records exceeded 69,000 records (the public bodies did not assert that provision in their initial response to the FOIA request). The circuit court initially denied that request and appointed a special master to review the responsive records, but later issued a ruling dismissing the case, finding that the request was unduly burdensome under 3(g) of FOIA.

The requester appealed, and the Appellate Court reversed the dismissal of the case. First, the Appellate Court determined that FOIA does not authorize a circuit court to appoint a special master to review records or to require a requester plaintiff to pay the costs of the special master. Second, the Court held that although the public bodies can rely on the "unduly burdensome" provision of FOIA to defend against a FOIA lawsuit, they must first give the requester an opportunity to narrow the request.

Quorum Forum Podcast Ep. 103: Zoning, Preemption, and Housing: Navigating the BUILD Plan

2026-03-10T08:35:00.001-05:00

Building on yesterday's blog post, Ancel Glink just released Quorum Forum Podcast Episode 103: Zoning, Preemption, and Housing: Navigating the BUILD Plan. In this episode, Ancel Glink attorneys Erin Monforti, David Silverman, and Greg Jones break down Governor Pritzker’s proposed BUILD Plan (Building up Illinois Development). This initiative intends to reduce costs and eliminate barriers to housing development, but it includes proposals that could significantly limit local authority over zoning, building codes, and fees. The team discusses what these potential statewide mandates could mean for the future of Illinois communities.

Highlights:

The BUILD Plan: An overview of the Governor’s February 2026 proposal to cut "bureaucratic red tape" through new legislative and regulatory standards.
"Middle Housing" Mandates: A look at bills that would require local governments to allow duplexes, triplexes, and townhomes in any area currently zoned for single-family homes.
Limits on Local Review: Discussion on provisions that would prevent municipalities from requiring special use permits or variances for middle housing if those same rules don’t apply to single-family homes.
Statewide Zoning Standards: The potential shift toward inflexible statewide rules for residential building heights, setbacks, and how much of a lot can be covered by a building.
Accessory Dwelling Units (ADUs): How proposed laws would normalize "granny flats" across the state, potentially making it easier for homeowners to get financing while increasing local density.
Standardizing Impact Fees: Assessing the move toward mandatory state formulas for school and park impact fees to make costs more predictable for developers.
Strict Permit Deadlines: New requirements for municipalities to complete plan reviews within 15 to 30 days, or else developers may hire their own third-party inspectors to do the work.
Public Comment: A critical update for FOIA officers regarding emails caught in spam filters. A recent court ruled that a request is considered "received" even if it is automatically quarantined by your IT system.

Introduction of BUILD Plan Legislation Proposes Statewide Housing Development Reform

2026-03-09T09:14:00.004-05:00

In mid-February, the Governor delivered his State of the State address and budget proposal for the 2027 State Fiscal Year. During his presentation, Governor Pritzker shared his concerns about the availability and cost of housing across Illinois, noting that “local regulations have made it too difficult and costly to build new housing” and citing “bureaucratic red tape” as an impediment to residential development activity. To combat these issues, the Governor announced the Building Up Illinois Development (BUILD Plan), an initiative to lower housing costs by making it more efficient and cost effective to build housing in Illinois. This initiative includes several legislative proposals that have since been introduced in the Illinois General Assembly.

House Bill 5626: Housing Omnibus

HB 5626 is a 40-page omnibus bill that includes a host of amendments to the Illinois Municipal Code and Illinois Counties Code addressing issues including impact fees, “middle housing” development, accessory dwelling units (ADUs), single-stair regulations, among others. In addition to HB 5626, several bills have been introduced in the Illinois Senate which propose the same substantive changes at an issue-by-issue level.

Senate Bill 4060: Middle Housing & Statewide Standards

SB 4060 proposes several changes to the Illinois Municipal Code with the express purpose of expanding housing choice and increasing the supply of “middle housing,” which includes duplexes, triplexes, fourplexes, cottage clusters, townhomes, attached courtyard housing, detached courtyard housing, and stacked flat-plexes. If enacted, SB 4060 would limit the imposition of local standards (including bulk, lot area, setbacks, and other restrictions) that are not “clear and objective” as defined in the Bill. The Bill also proposes to prohibit municipalities from enforcing standards that impose requirements on middle housing that are more stringent than those applicable to detached single-family units and restricts the use of “discretionary review,” such as special use permitting and variations for middle housing unless the same process is required for single-family homes.

Senate Bill 4061: Single-Stair Reform

SB 4061 provides that, beginning January 1, 2027, no building code adopted by a municipality may prohibit a residential building from having a single stairway serving as an exit for all units if the building exhibits certain features (limited height, sufficient automatic sprinkler installation, and ample emergency escape and rescue openings for residents).

Senate Bill 4062: Statewide Impact Fee Calculation

SB 4062 proposes a plan to implement statewide municipal impact fee calculations. The Bill, if approved, would authorize and direct the Illinois Department of Commerce and Economic Opportunity (IDCEO) to issue mandatory statewide formulas, multipliers, and other tools for calculating and imposing impact fees at the local level. The Bill sets forth several deadlines for compliance with its provisions, including an overall 30-month timeframe for municipalities to begin calculating impact fees in accordance with the formulas and guidance materials to be published by the IDCEO.

Senate Bill 4063: Third-Party Plan Review

SB 4063 provides uniform deadlines for municipal building permit review and inspections, proposing the following deadlines:

o Plan Review:

§ A municipality must complete its initial plan review (undefined term) within 15 business days after receipt of an application for a 1-family or 2-family residential project.

§ A municipality must complete its initial plan review (undefined term) within 30 business days after receipt of an application for a multifamily, mixed-use, or commercial project.

§ Any subsequent reviews must be completed within 10 business days of the revisions being submitted.

o Inspections: a municipality must conduct any required inspection within 2 business days of receiving a request.

Under SB 4063, if a municipality failed to comply with the plan review and inspection deadlines, an applicant would be able to retain a qualified third-party professional to conduct the review or inspection. These professionals must be licensed architects or engineers and be certified under one of several national building code standards. Upon submission of third-party plan reviews and inspection reports, municipalities would be limited in their ability to audit the reviews and impose additional standards for projects.

Senate Bill 4064: Parking Reform

SB 4064 proposes to limit municipal parking requirements starting January 1, 2027. Specifically municipalities would be prohibited from requiring more than 0.5 parking space per multifamily dwelling, or more than 1 parking space per single-family home. Municipalities would also be restricted from establishing parking minimums for certain uses including affordable housing projects, dwellings smaller than 1,500 square feet, and others.

Senate Bill 4071: Accessory Dwelling Units (ADUs)

SB 4071 provides that every municipality must permit ADUs in all zoning districts allowing single-family dwellings without additional requirements related to lot size, setbacks, aesthetic standards, design review, frontage, space limitations, or controls beyond those imposed for single-family homes. The Bill also limits other ADU regulations, including by prohibiting municipalities from requiring a familial relationship between occupants of an ADU and the principal structure on a lot.

Again, the proposals in Senate Bills 4060–4064 and Senate Bill 4071 have also been introduced in the Illinois House through House Bill 5626. All of the legislative initiatives summarized above also include express language preempting home rule units from regulating in a manner more restrictive to the various housing initiatives than provided in the bills. Readers should note that these bills were only recently introduced, and some (or all) may be subject to amendments, debate, and delays as they make their way through the General Assembly. We will be tracking this legislation to provide key updates as the spring legislative session gets underway.

Post Authored by Erin Monforti, Ancel Glink

Quorum Forum Podcast Ep. 102: Web Accessibility

2026-03-05T09:11:00.002-06:00

Ancel Glink's Quorum Forum Podcast just released Episode 102: Web Accessibility.

In this episode, Jamie Wilkey, a Partner at Lauterbach & Amen, joins Ancel Glink’s Katie Nagy to discuss the Department of Justice’s final rule on web accessibility under Title II of the Americans with Disabilities Act (ADA). They explore the new requirements for state and local governments to ensure their web content and mobile applications are accessible to individuals with disabilities, and offer practical advice on implementation, technical standards, and compliance deadlines (starting on April 24, 2026 for some larger governments).

Highlights:

The Technical Standard: An overview of WCAG 2.1 Level AA, the benchmark for digital accessibility compliance.

Defining Web Content: Understanding how the rule applies to websites, mobile apps, social media, online payment portals, and digital documents like meeting minutes and agendas.

Compliance Deadlines: Key dates for local governments (April 24, 2026 for populations over 50,000; April 26, 2027 for smaller entities and special districts).

Practical Implementation: Steps for success, including identifying an internal team, conducting an inventory of digital assets, and prioritizing remediation.

Exceptions and Limitations: A breakdown of what content is exempt, such as archived web content, pre-existing conventional documents, and certain third-party content.

Risk Management: Analyzing the legal, financial, and reputational risks of non-compliance.

Public Comment: A discussion on the Seventh Circuit's decision in O’Donnell v. City of Chicago regarding vehicle forfeiture programs and unconstitutional takings.

Resources:

Fact Sheet: New Rule on the Accessibility of Web Content and Mobile Apps Provided by State and Local Governments

DOJ Guidance: First Steps Toward Complying with the ADA Title II Web and Mobile Application Accessibility Rule

Municipal Minute: City's Vehicle Forfeiture Program Not an Unconstitutional Taking

Court Finds FOIA Search Reasonable But Sends Request for Civil Penalties for Late Response Back to Circuit Court

2026-03-03T08:30:00.001-06:00

An Illinois Appellate Court recently found a public body's search for records in response to a FOIA request to be reasonable and adequate in Tobias v. City of Chicago's Office of Mayor.

An independent journalist submitted a FOIA request to the Office of Mayor for text messages between the Mayor and the President of the Chicago Teachers Union for the period from the date the Mayor took office to the date the FOIA was processed and all text messages sent or received by the Mayor's Chief of Staff for two specified dates.

A City FOIA officer extended the time for response and initiated a search of texts but the City did not respond by the extended due date. Shortly thereafter, the journalist filed a lawsuit against the City claiming it violated FOIA by not responding to the FOIA request. The City produced four pages of text messages as part of its response to the lawsuit, arguing that the case was now moot, and that it could not have produced the records by the original deadline because it did not possess them at that time. The circuit court ruled in the City's favor, finding that the City did not have the records in its possession at the time the FOIA response was due since the records had not been turned over to the City until after the deadline.

On appeal, the journalist argued that the City improperly narrowed its search for records, both in scope and time-frame. The Appellate Court disagreed, finding that the City's search was both reasonable and adequate in scope and time and there was no statutory requirement that records existing after the date of the City's search be provided. However, the Court determined that the circuit court needed to reconsider the journalist's request for civil penalties against the City for failing to respond to the FOIA request in a timely matter and remanded the case back for further proceedings.

Court Rules in Favor of Public Body in FOIA Case

2026-03-02T08:44:00.000-06:00

In 2023, a FOIA requester mailed over 40 letters to the Illinois Secretary of State (ILSOS) seeking copies of various records. After ILSOS did not respond to his requests, the requester sued ILSOS alleging various FOIA violations. ILSOS filed a motion to dismiss the complaint, supported by the affidavit of its FOIA Officer, because (1) the requester failed to comply with ILSOS’s FOIA regulations, because the requests were improperly addressed—not directed to the designated address for ILSOS’s FOIA officer as identified on its forms, and (2) because ILSOS never received the FOIA requests, it did not violate FOIA. The circuit court ruled in favor of ILSOS, and the requester appealed. On appeal, the Fifth District Court of Appeals upheld the circuit court’s ruling in favor of ILSOS. Lenard v. Office of the Illinois Secretary of State.

The appellate court determined that Section 3(h) of FOIA expressly authorizes public bodies to establish FOIA regulations governing the time, place, and person from whom records may be requested. In this case, because the requester failed to comply with ILSOS’s FOIA regulations for submitting FOIA requests by sending his requests to the wrong address rather than the address prescribed by ILSOS in its forms, the appellate court determined that ILSOS never received his requests within the meaning of FOIA, and ILSOS’s duty to respond was never triggered. Furthermore, because the requester’s FOIA requests were improperly submitted to ILSOS, the requester was never denied access to public records, and ILSOS did not improperly deny the requester access to records in violation of FOIA.

Post Authored by Eugene Bolotnikov, Ancel Glink

Appellate Court Sends FOIA Challenge Back to Circuit Court

2026-02-23T08:30:00.001-06:00

In 2022, a requester sued a county board, a county sheriff, and a county’s state’s attorney’s office (defendants) for several alleged FOIA violations. During the litigation, defendants requested the circuit court to: (1) allow defendants to designate one of the requester’s FOIA requests as unduly burdensome because defendants identified over 69,000 pages of responsive records to the request, or (2) in the alternative, to perform an in camera review of defendants responsive records to assess whether FOIA exemptions applied to the records. The circuit court appointed a special master to review defendants’ 69,000 pages of records to determine which parts of the records qualified for exemptions, and ordered the requester to pay the special master’s retainer prior to the start of their services. The requester did not make the court-ordered retainer payment, which led the circuit court to rule in favor of defendants, finding that the requester’s FOIA request was unduly burdensome, and that the requester failed to comply with the court’s prior order requiring pre-payment of the special master’s fees for review services.

After the requester appealed the circuit court’s ruling, an Illinois Appellate Court: (1) held that the circuit court erred when it appointed a special master and required the requester to pay the special master’s review services fees, and (2) ordered the circuit court to re-instate the requester’s FOIA lawsuit and conduct that proceeding in accordance with FOIA. Dorman v. Madison County.

The Appellate Court reasoned that FOIA places the burden of justifying nondisclosure squarely on public bodies, and that FOIA contemplates that the court itself will resolve disputes concerning exemptions and disclosure. The Appellate Court determined that the circuit court’s inherent authority to control their proceedings may not be exercised in a way that conflicts with, or expands beyond, a legislatively prescribed statutory scheme. Here, the Appellate Court determined that the FOIA statute does not permit courts to (i) delegate their express statutory in camera review responsibilities to third parties, (ii) impose compliance or review-related costs on a requester, or (iii) condition the continuation of a requester’s FOIA action on their payment for special master services.

Post Authored by Eugene Boltnikov, Ancel Glink

In the Zone: Appellate Court Rules in Favor of Village in TIF Dispute with Schools

2026-02-19T08:30:00.005-06:00

In 2004, a village in Illinois established a tax-increment financing district (TIF #1) to revitalize its town center. In 2021 (6 years before the expiration of TIF #1), the village passed several ordinances to create a new TIF district comprised entirely of parcels of land that were previously included in the original TIF district’s redevelopment area (TIF #2). The majority of the parcels in TIF #2 are owned by a local hospital network, which entered into a redevelopment agreement with the village to increase parking for its facilities and facilitate the development of a mixed-use commercial building. Due to delays in the approval processes, the redevelopment of the hospital site began prior to adoption of the ordinance establishing TIF #2.

Two local school districts filed a lawsuit against the village, claiming that the newly established TIF #2 was invalid because it did not satisfy the statutory requirements for a “conservation area” subject to TIF treatment. The school districts claimed that the ongoing redevelopment activity by the hospital (prior to establishment of TIF #2) showed there was no need for tax-increment financing to spur development. Additionally, the school districts claimed that the process of removing parcels from TIF #1 only to include those same parcels in TIF #2 was an unlawful attempt to extend the 23-year lifespan imposed for TIF districts under the Tax Increment Allocation Redevelopment Act (Act).

The trial court ruled in favor of the village, finding it adequately established that the area comprising TIF #2 met the minimum criteria to be deemed a “conservation area” eligible for tax-increment financing. More specifically, the trial court determined that the village had shown there was (1) a lack of community planning, (2) a lagging equalized assessed value (EAV) in the proposed TIF #2 area compared with the rest of the village, and (3) deterioration of parcels within the TIF #2 area. The trial court also determined that the de-TIF/re-TIF process of removing parcels from one TIF district to enroll them in another was not prohibited by the Act.

The school districts appealed the trial court’s decision, and the Appellate Court upheld the ruling in favor of the village. On the issue of TIF #2’s designation as a conservation area, the Appellate Court first determined that the village had not erred in finding that the designated area would not reasonably be anticipated to be developed without implementation of TIF #2 and the associated redevelopment plan. While the hospital campus was being actively redeveloped when TIF #2 was established, the Court determined that this activity was clearly supported by the promise of tax-increment financing—in other words, the redevelopment activity and establishment of TIF #2 worked in tandem to stimulate revitalization of the site. The Court further affirmed that the village properly established the 3 eligibility criteria (lack of planning, lagging EAV, and deterioration) to designate TIF #2 as a conservation area.

The Appellate Court also determined that the de-TIF/re-TIF process for the parcels removed from TIF #1 and enrolled in TIF #2 was valid. The Court acknowledged that, to extend the life of a TIF district, municipalities must seek approval from the Illinois General Assembly. However, the Court found TIF #2 was sufficiently distinct from TIF #1, and therefore the de-TIF/re-TIF was not an invalid extension without legislature approval. The Appellate Court observed that nothing prohibits a parcel of land from being placed in a new TIF district after removal from another. Furthermore, the Court noted that the base EAV values had been reset upon the village’s creation of TIF #2, which effectively allowed the other local taxing bodies to receive tax revenue based on EAVs calculated in 2021 rather than 2004. Therefore, the facts and circumstances underlying the creation of TIF #2 did not suggest an unlawful extension of the original TIF #1.

Board of Education of Winfield S.D. 34, et al. v. Village of Winfield

Post Authored by Erin Monforti, Ancel Glink

Appellate Court Rules in Favor of Government in Malicious Prosecution Case

2026-02-18T08:30:00.000-06:00

In Hill v. Cook County, an Illinois Appellate Court upheld a circuit court’s ruling in favor of government defendants in a malicious prosecution claim.

An arrestee sued the county, the county sheriff, and a municipality and various police officers for claims arising from an arrest in connection with an alleged armed robbery. The arrestee claimed that upon his arrest, he entered into an agreement with police that he would not be rearrested or charged in connection with the incident if he passed a polygraph test.

At his criminal trial, the court found the agreement unenforceable because a prosecutor was not involved in the agreement. Subsequently, the arrestee was sentenced to lengthy prison sentences for murder, attempted murder, and armed robbery convictions.

He appealed his conviction, arguing that the court erred in finding his arrest agreement with police invalid. While his appeal was pending, the Illinois Supreme Court decided People v. Stapinski, holding that prosecutors could be bound by agreements made by police officers, and his agreement with police was later found valid and his conviction was vacated.

After his conviction was vacated, he filed an action for malicious prosecution against the government defendants. Because the vacation of his conviction was based on contract law and due process principles, and not the probability of his innocence, the Appellate Court held that the government defendants could not be held liable for malicious prosecution, and the trial court's ruling in favor of the government defendants was proper.

Post Authored by Luigi Laudando & Julie Tappendorf, Ancel Glink

Appellate Court Addresses Claims Against Municipality by Tree Vendor

2026-02-17T08:30:00.002-06:00

An Illinois Appellate Court dismissed most of the claims in a lawsuit filed by a vendor against a municipality, although it allowed an unjust enrichment claim and a fradulent misrepresentation claim to move forward in the circuit court. Johns Pro-Tree Service v. Village of Dolton.

A mayor and two village public works employees reached out to the president of a tree service company for emergency tree trimming and removal service related to a storm in June 2023. After the parties agreed to a price, the tree company completed the work. Subsequently, the parties agreed to continue the services to the village, and the village paid the full invoice amount. On September 25th, the company submitted another invoice for their work, but was told that none of the village’s vendors would be paid for their recent work due to budget restrictions. The company filed a lawsuit against the village claiming breach of contract, a violation of the Local Government Prompt Payment Act, fraudulent misrepresentation, quantum meruit, unjust enrichment, and promissory estoppel. The circuit court dismissed the case in its entirety, finding that the village was immune from liability and the alleged contract was not enforceable because it had not been approved or ratified by the village's board of trustees.

On appeal, the Appellate Court upheld the circuit court's dismissal of the breach of contract, Prompt Payment Act, quantum meruit, and promissory estoppel claims.

On the breach of contract claim, the Appellate Court held that the complaint did not show that the contract was approved by the board of trustees or that the board had delegated contracting authority to the mayor or other officials or otherwise authorized the contract with the tree service contract. As a result, the tree service company's claim that the village had breached a contract with the company was properly dismissed by the circuit court.

The Appellate Court also held that because the breach of contract claim was properly dismissed, the Local Government Payment Act claim was also properly dismissed.

On the company's quantum meruit claim, the Appellate Court found that the allegations in the complaint were insufficient to show that the board of trustees authorized the proper officials to accept or approve the terms of the transaction with the tree service company.

The Appellate Court also upheld the dismissal of the company's promissory estoppel claim finding that the company did not establish that the representatives of the village involved with the tree company had authority to make any representations or promises to the company.

However, the Appellate Court disagreed with the circuit court on the dismissal of the fraudulent misrepresentation claim, finding that the village did not meet the burden of proof by showing they were immune under the Tort Immunity Act.

The Court also disagreed with the dismissal of the tree company's unjust enrichment claim, finding that this claim was adequately pled in the complaint to survive a dismissal.

As a result, the Court sent the case back to the circuit court for further proceedings on the company's fraudulent mispresentation and unjust enrichment claims.

Post Authored by Natalie Cheung & Julie Tappendorf, Ancel Glink

Appellate Court Upholds Demolition Order But Limits Municipal Fines

2026-02-12T08:30:00.001-06:00

In County of DuPage v. Arjmand, an Illinois Appellate Court upheld a demolition order issued by a circuit court in favor of a county, but reversed portions of the circuit court's order imposing fines on the property owner.

A property owner owned a partially constructed and vacant property. According to the county, the property contained numerous unsafe and hazardous conditions, including broken windows, graffiti, mold, and structural issues, and became a site for trespassing and other illicit activities. After the owner failed to address all of the code issues, the county filed a complaint against the owner alleging that the residence was an unsafe structure, public nuisance, lacked a valid building permit, and violated various provisions of the International Property Maintenance Code.

The circuit court ruled in favor of the county on all counts in 2021 and issued a demolition order for 2022. The court also imposed fines, fees, and costs against the property owner. The owner appealed, raising four issues on appeal: (1) the validity of demolition order, (2) the grant of summary judgment in favor of the county, (3) the validity of the imposed fines, and (4) the trial judge’s refusal to recuse himself.

The Appellate Court upheld the demolition order in favor of the county, finding that despite the owner taking some remedial measures, the property remained dangerous and unsafe, and the owner had more than reasonable time to repair the property.

As to the owner's appeal of the fines imposed by the court, the Appellate Court determined that fines for ordinance violations must be calculated for violations up to the date of the court order, not after the order is issued. The court also rejected the issuance of prejudgment fines on certain of the counts and sent the case back to the circuit court for further proceedings.

The Appellate Court also rejected the property owner's claim that the judge should have recused himself.

Post Authored by Luigi Laudando & Julie Tappendorf, Ancel Glink

PAC Finds FOIA Violation in Response to Request for Termination Letter

2026-02-11T08:30:00.001-06:00

A reporter submitted a FOIA request to a State's Attorney's Office (SAO) seeking records about a former SAO employee who was terminated and criminally charged for alleged misconduct while working at the SAO. The SAO withheld a responsive termination letter on the basis that the letter, if disclosed, would interfere with a pending criminal prosecution and picking of a jury.

After the requester submitted a request for review with the Illinois Attorney General’s Public Access Counselor (PAC), the PAC issued its second binding opinion of 2026 concluding that the SAO improperly withheld the termination letter. PAC Op. 26-002.

First, the PAC determined that FOIA’s investigatory exemptions in Section 7(1)(d) only apply to records either (1) created in the course of administrative enforcement proceedings, or (2) if the record is maintained by a correctional or law enforcement agency for law enforcement purposes. In this case, the PAC determined that the termination letter was not created during the course in the course of an administrative enforcement proceeding. The PAC also determined that the letter was not a record maintained by the SAO "for law enforcement purposes,” because the letter was a personnel record created by the SAO to document a former employee’s termination. Because the withheld letter was not a record maintained by the SAO "for law enforcement purposes,” the PAC determined that FOIA’s investigatory exemptions in Sections 7(1)(d)(i) and 7(1)(d)(iii) did not apply to allow the SAO to withhold the record.

Second, the PAC determined that the SAO did not demonstrate that disclosing the letter would interfere with law enforcement proceedings or create a substantial likelihood that a person would be deprived of a fair trial or impartial hearing. Although the SAO argued that the court had not yet ruled on the admissibility of information in the letter, the PAC reasoned that FOIA does not provide a blanket exemption for records that may contain information that may be inadmissible in court. The PAC found that the SAO did not illustrate that revealing previously undisclosed information in the letter is likely to garner intense pre-trial publicity that could taint the pool of potential jurors in the county. Even if some potential jurors were exposed to the letter, the PAC argued that the SAO could use judicial safeguards, like voir dire, to identify and exclude potential jurors whose knowledge of relevant information may taint their impartiality. While the letter contains allegations that have not been publicly disseminated or reported on, the PAC reasoned that disclosing the letter would not interfere with the prosecution of the former SAO employee, because it does not contain highly specific details (e.g., identities of witnesses, sensitive details that would materially impact witness testimony, or evidentiary proof or sources of evidence) that would interfere with a law enforcement proceeding.

Post Authored by Eugene Bolotnikov, Ancel Glink

Quorum Forum Podcast Ep. 101 - Navigating AI's Impact on the Modern Workplace

2026-02-10T08:30:00.001-06:00

Ancel Glink's Quorum Forum Podcast just released Episode 101 featuring Mysi Hall's recent ILCMA presentation, “Digital Decisions: Navigating AI’s Impact on the Modern Workplace.” In this podcast, Mysi examines the current legal landscape surrounding the use of artificial intelligence in labor relations and employment practices.

Highlights:

The Legal Landscape: Overview of federal and state regulations, including EEOC guidelines on Title VII and the ADA.
Illinois Specifics: A look at the AI Video Interview Act (AIVIA) and the 2026 amendments to the Illinois Human Rights Act.
Bias and Mitigation: Understanding automation bias, selective adherence, and real-world examples of algorithmic discrimination.
Labor Relations: How major unions (ILA, SAG-AFTRA, AFL-CIO) are negotiating AI safeguards and transparency.
Best Practices: Practical steps for employers, including the NIST Risk Management Framework and the importance of human oversight.

Clean and Reliable Grid Affordability Act’s Impact on Units of Local Government and Road Districts

2026-02-05T08:30:00.000-06:00

On January 8, 2026, Governor Pritzker signed the Clean and Reliable Grid Affordability Act (CRGA) into law. With an effective date of June 1, 2026, the Act brings several changes to state energy policy intended to develop new energy resources.

The Act amends state statute to restrict the ability of units of local government and road districts to impose fees, fines, or other payment obligations for road use agreements with a commercial wind energy facility or a commercial solar energy facility owner (including the facility developer).

Previously, Section 5-12020 of the Counties Code stated that road-related fees, permit fees, or other charges imposed under a road use agreement must be reasonably related to the administration cost of such agreement.

Under the new amendment, a road district or other unit of local government is prohibited from requiring any permit fees, fines, or other payment obligations as a condition of a road use agreement, unless the reasonable permit fee or payment obligation reflects the actual expenses incurred. These expenses must relate to the negotiation, execution, construction, or implementation of the road use agreement.

The new amendment also prohibits a road use agreement from requiring a facility owner to pay or perform any road work that is not specifically and uniquely related to the road improvements required for the facility or the restoration of roads used by the facility owner during construction-related activities.

In effect, the Act constrains the scope of road use agreements and the ability of units of local government and road districts to impose fees related to commercial alternative energy facilities. However, Section 5-12020 of the Counties Code does not expressly provide that it is a denial and limitation on home rule powers and functions.

Authored by Luigi Laudando and Katie Nagy, Ancel Glink

More Bills Introduced in General Assembly to Amend FOIA

2026-02-04T08:30:00.001-06:00

On January 20th, we reported on a number of bills introduced in the Illinois General Assembly this term that would, if approved, amend various provisions of FOIA. Since that post, the General Assembly has been quite busy and has introduced many more bills that propose to amend FOIA, many of which appear to be designed to address the recent proliferation of "mass" requests submitted by organizations that seek the same records from numerous numerous public bodies.

HB 4597: If approved, this bill would amend FOIA to authorize a public body to impose a fee on a requester for staff time incurred in redacting body camera recordings, at the lowest paid employee's pay rate. The bill has some exceptions where a fee may not be imposed, including (1) where the requester certifies that it will not use the recording for financial purposes; or (2) the requester is involved in the incident; or (3) the recording depicts an officer-involved shooting; or (4) the public body fails to provide the requester with an estimate of the applicable fees as required by the bill.

HB 4681: If approved, this bill would amend FOIA to add provisions relating to "mass" requesters and "vexatious" requesters and expand the definition of "commercial" requester. The bill would also require requesters to notify the public body before filing a lawsuit against the public body for an alleged violation of FOIA. The bill would provide a process for public bodies to petition the Public Access Counselor of the Attorney Generals Office (PAC) for relief from "vexatious" requesters, and also provide additional time to respond to "mass" requesters.

HB 4682: If approved, this bill would amend FOIA to provide that repeated requests for commercial purposes are deemed unduly burdensome if the reuqests are from the same person and seek similar or updated records.

HB 4683: If approved, this bill would amend FOIA to add language regarding "mass" requesters and provide additional time for the public body to respond to requests from requesters that fall into that category.

HB 4684: If approved, this bill would amend FOIA to modify the definition of "commercial purpose" and add a new provision for "purposeless mass requests."

HB 4704: If approved, this bill would amend the Student Confidentiality Reporting Act and FOIA to prohibit the release of information submitted to school helplines.

SB 3218: If approved, this bill would amend FOIA to modify provisions relating to law enforcement and arrest and booking records, increase the allowable fee for copies from 15 cents to 25 cents, and modify the amount public bodies can charge for staff time in searching for and retrieving records requested for commercial purposes.

None of these bills have passed yet, but we will keep you posted if any of these move forward.

Seventh Circuit Grants Qualified Immunity to Police Officers

2026-02-03T08:30:00.001-06:00

In Johnson v. Edwards, an arrestee sued four police officers alleging they violated his constitutional rights after he was arrested for disorderly conduct.

Johnson was arrested after he attempted to enter an area that had been taped off for police investigation of a crime scene. When the police officers ordered Johnson to leave the area, he became agitated and began to yell at the officers. Johnson refused to leave and the officers arrested Johnson, put him in the squad car, and drove him to the police station. Johnson had refused to wear his seatbelt on the drive there. On the way there, Johnson asked the officer to slow down. The officer quickly slowed the car down to stop at a red light which caused Johnson to lurch forward and hit his head on the divider. Two minutes later, when they arrived at the station, the officers realized Johnson had been knocked unconscious. He was taken to the hospital where he was diagnosed and treated for a cut lip.

Johnson was charged with disorderly conduct for failing to obey a police officer. After the charges were dropped, he sued the officers involved in his arrest, claiming the following constitutional violations: (1) false arrest in violation of the Fourth Amendment; (2) state-created danger in violation of the Fourteenth Amendment’s Due Process Clause; (3) excessive use of force for the “rough ride” to the station; (4) failure to provide adequate medical care. Johnson also brought a claim for malicious prosecution. The district court ruled in favor of the police officers, finding they were immune from Johnson’s claims based on qualified immunity.

On appeal, the Seventh Circuit Court of Appeals upheld the ruling in favor of the officers. The Seventh Circuit found that Johnson had not established a violation of his constitutional rights because: (1) the officers had probable cause to arrest Johnson for engaging in disorderly conduct when he refused to leave the crime scene; (2) the officers had not placed Johnson in a position of danger, or violated an established constitutional right, by allowing him to ride to the station without a seatbelt on; (3) the facts did not support a finding that the ride to the station constituted an excessive use of force; and (4) the officers had called the paramedics as soon as they realized Johnson was hurt, so Johnson could not establish that they acted unreasonably. Because Johnson failed to establish a violation of a constitutional right, the Seventh Circuit found the officers were entitled to qualified immunity for their actions.

As to Johnson’s malicious prosecution claim, the Court found that the officers had probable cause to arrest Johnson for disorderly conduct and dismissed this claim.

Post Authored by Alexis Carter

Court Finds Response to FOIA Request That Was Quarantined by Email Service Untimely

2026-02-02T08:30:00.001-06:00

An Illinois Appellate Court recently issued an opinion on the timeliness of FOIA responses where a request is quarantined by a public body's email software service. Balzer v. Northeast Illinois Regional Commuter Railroad Corporation.

On July 31st, a requester emailed a FOIA request to the public body's FOIA officer seeking various contract records. However, the FOIA officer did not learn about the FOIA request until the next business day because the public body’s third-party email software service (Mimecast) flagged the email as suspicious and quarantined the FOIA request in its security queue. On August 1st, Mimecast sent the public body’s FOIA account a notification that the FOIA request was held in queue, and the public body’s FOIA officer received the FOIA request that day. The public body reached out to the requester on August 1st to ask the requester to narrow the request because it was unduly burdensome. The requester refused to narrow the request, and the public body formally denied the FOIA request as unduly burdensome pursuant to Section 3(g) of FOIA on August 8th, the sixth business day after the request was sent, but only the fifth business day after the FOIA officer became aware of it.

The requester sued the public body, claiming the public body’s response was untimely. The circuit court ruled in favor of the public body, finding that FOIA’s five-business-day response window only begins when the public body actually receives and acknowledges receipt, which according to the circuit court meant that the response was due on August 8th.

However, on appeal, the Appellate Court ruled in favor of the requester, finding that the public body received the request on July 31st (the day that Mimecast received the request and quarantined it), so the public body's August 8th response was untimely under FOIA.

The Appellate Court acknowledged that FOIA does not define when a FOIA request is deemed received by a public body. However, the Court found that the request at issue was “received” by the public body when Mimecast received it on July 31st, regardless of whether Mimecast or the public body were aware of it, and regardless of whether Mimecast was operated by a third-party rather than by the public body. The Appellate Court held that FOIA does not "toll" a public body’s five-business-day response obligation because a system that the public body itself created or adopted caused an internal delay in a request reaching its FOIA officer, so the public body’s August 8th denial of the request was untimely.

The Appellate Court also held that the public body waived its ability to deny the request as unduly burdensome pursuant to Section 3(g) of FOIA because its response was untimely.

Post Authored by Eugene Bolotnikov & Julie Tappendorf, Ancel Glink

Ancel Glink at the IAPD/IPRA 2026 Conference

2026-01-28T08:30:00.002-06:00

For all of our park officials and employee readers who will be in attendance at the IAPD/IPRA conference this week, we hope you can stop by one or more of the sessions at which Ancel Glink attorneys will be presenting:

Thursday, 1/29/2026

1 - 2 pm - Session 112 - Real Estate 101, Scott Puma & David Silverman (Ancel Glink)

1 - 2 pm - Session 120 - Can We and Should We Have Video Surveillance in Parks & Facilities?, Megan Mack & Tyler Smith (Ancel Glink)

1 - 2 pm - Session 126 - From Ballot To Victory: Strategies for Successful Referendums, Keri-Lyn Krafthefer (Ancel Glink), Lauren Raspanti & Paul Henley

Friday, 1/30/2026

8:30 - 9:30 am - Session 110 - Legal/Legislative I, Derke Price (Ancel Glink) & Jason Anselment

3:30 - 4:30 pm - Session 119 - Regulating Controversial Park Activities, Eugene Bolotnikov, Katie Nagy & Tyler Smith (Ancel Glink)

Saturday, 1/31/2026

10:45 - 11:45 am - Session 115 - Be Prepared for Your First Amendment Audits, Erin Monforti (Ancel Glink)

10:45 - 11:45 am - Session 118 - Park District Finance - It's Not Intuitive, Adam Simon (Ancel Glink) & Mari-Lynn Peters

12:30 - 1:30 pm - Session 116 - Understanding Social Media: Facebook? Instagram? X?, Erin Monforti (Ancel Glink)

12:30 - 1:30 pm - Session 131 - Solar and Green Energy Options, Adam Simon (Ancel Glink), Erik Brown & Shawn Ajazi

12:30 - 1:30 pm - Session 133 - Managing Teen Takeover Events: Strategies, Challenges, and Collaborative Solutions, Derke Price (Ancel Glink) & Chief Steven Schindlbeck

12:30 - 1:30 pm - Session 129 - Boardmanship Essentials Part I, Scott Puma (Ancel Glink)

2 - 3 pm - Session 130 - Boardmanship Essentials Part II, Adam Simon (Ancel Glink)

2 - 3 pm - Session 122 - You Really Should Read Your Board Policy Manual (And Keep It Updated), Scott Puma & Erin Monforti (Ancel Glink)

2 - 3 pm - Session 128 - Parks Role in Successful Planning and Economic Development, David Silverman (Ancel Glink), Dan Bolin (Ancel Glink) & Jodi Mariano

Fourth Circuit Denies Injunctive Relief for Public Comment Interruptions

2026-01-27T09:09:00.002-06:00

The Fourth Circuit Court of Appeals issued a ruling on public comment at meetings in Platt v. Mansfield. Although the Fourth Circuit does not cover Illinois so this ruling is not binding on Illinois government bodies, the case is interesting because it provides a different perspective from the recent Public Access Counselor ruling (PAC Op. 26-001) that we reported on recently that struck down a public comment policy that prohibited comments that attacked public employees or officials.

The case involved a school board that offered an opportunity for public comment at its school board meetings pursuant to a school board policy. That policy prohibited public comment that targets, criticizes, or attacks individual students at meetings, and stated that these type of concerns must be raised privately to the appropriate school official. A group of individuals attended a school board meeting to express their concerns about a student who had been arrested for threats to another classmate, and claimed they were interrupted or not allowed to speak after the board ended the public comment period because of the content of their speech. They filed a lawsuit against the school board claiming that the school board discriminated against their viewpoint and that the board's public comment policy was unconstitutionally vague in violation of their free speech rights under the First Amendment. The district court denied the plaintiffs' request for a preliminary injunction, and they appealed.

On appeal, the Fourth Circuit Court of Appeals upheld the denial of injunctive relief, finding that the plaintiffs did not establish a sufficient likelihood of success on the merits of their claims to support their request for a preliminary injunction. The Court found that the public comment period of the school board meeting was a "limited public forum" and the school board had the right to establish content-neutral restrictions on the speach presented during that public comment period so long as those restrictions were not discriminatorily applied. The Court determined that the school board only interrupted speakers when they violated the school board's policy that prohibits comments that critized an individual student. The Court rejected the speakers' argument that they were discriminated against, finding that the interruptions during their comments were for violations of a facially constitutional speech policy.

Court Finds City Immune from Lawsuit in Case Involving Missing Person

2026-01-26T09:14:00.005-06:00

An Illinois Appellate Court determined that a municipality had immunity from a lawsuit brought by a mother who claimed she suffered emotional distress caused by the municipality's failure to assist her in locating her missing daughter. Specifically, the court held that the city had immunity from liability for "failure to provide adequate police protection or service" under section 4-102 of the Tort Immunity Act. Bailey v. City of Chicago.

A mother called 911 to report her daughter missing after she went to her daycare center and the child was missing. She also asked the police to issue an Amber Alert. No police met with her at the daycare and no Amber Alert was issued, although her daughter was found about two hours after she was reported missing. The mother filed a lawsuit against the city claiming the city breached a duty of care. After the circuit court dismissed the complaint and denied her request to amend the complaint, she appealed to the Appellate Court, which upheld the circuit court's ruling, finding that her claims were barred by the Tort Immunity Act.

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