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Illinois Supreme Court Affirms Ruling that Home Rule Ordinances May Not Contravene Prior Court Interpretations of State Statutes

Mar 2, 2022

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In International Association of Fire Fighters, Local 50 v. City of Peoria 2022 IL 127040, the Illinois Supreme Court held that the City of Peoria may not use its home rule authority to pass an ordinance inconsistent with the requirements of the Public Safety Employee Benefits Act (“PSEBA”). The City’s ordinance concerning the line of duty disabilities was amended to create definitions for certain undefined terms in PSEBA including the terms “catastrophic injury,” “gainful work,” and “injury.” In particular, the City attempted to define “catastrophic injury” as “[a]n injury, the direct and proximate consequences of which permanently prevent an individual from performing any gainful work.”  The City argued that it had the power to define those terms pursuant to its home rule authority, despite the fact that prior Illinois Supreme Court case law had applied a different definition of the term “catastrophic injury” in Krohe v. City of Bloomington, 204 Ill. 2d 392 (2003) (holding that “catastrophic injury” is “synonymous with an injury resulting in a line-of-duty disability under section 4-110 of the [Illinois Pension] Code” at 40 ILCS 5/4-110).

The Supreme Court found that the City’s ordinance was not a valid exercise of home rule authority, ruling that Krohe remains the prevailing law for defining “catastrophic injury” under the Public Safety Employee Benefits Act and may not be contradicted by home rule unit ordinances.

In its decision, the Supreme Court explained that while a home rule unit may properly adopt administrative procedures, it cannot redefine substantive terminology in contravention of prior Supreme Court rulings. The Court reiterated the long-held rule that, after the Supreme Court has construed a state statute, the interpretation of that statute becomes, in effect, part of the statute itself until the legislature amends the statute to read otherwise. 

Please contact a Robbins Schwartz attorney if you have any questions concerning the Supreme Court’s ruling.