three-readings requirement in Illinois

2025While separation of powers is a valid doctrine and a presumption of legislative regularity is its proper corollary, this court should reserve the right of review to ensure the General Assembly’s compliance with constitutional mandates.’ ” Caulkins, 2023 IL 129453, ¶ 95 (quoting Dunigan, 165 Ill. 2d at 257-58 ). ¶ 62 In Caulkins, Justice Holder White, in a dissent that I joined, also recognized that since Dunigan this court has noted the legislature has “ ‘shown remarkably poor self discipline in policing itself in regard to the three-readings requirement.’ ” Id. ¶ 96 (quoting Friends of the Pa

2025App. 3d 974, 992 (2006), Doe v. Lyft, Inc., 2020 IL App (1st) 191328 , ¶¶ 51-55, Accuracy Firearms, LLC v. Pritzker, 2023 IL App (5th) 230035, ¶¶ 36-46 , First Midwest Bank v. Rossi, 2023 IL App (4th) 220643, ¶¶ 220-41 , and Rowe v. Raoul, 2023 IL 129248, ¶ 8 (noting the plaintiffs raised a three-readings rule claim in the circuit court)). ¶ 63 Because I continue to wholeheartedly agree with the dissenting opinion in Caulkins, I restate its compelling analysis here: “In Friends of the Parks, 203 Ill. 2d at 329 , this court noted it is ‘ever mindful of its duty to enforce the constitution of th

2025While separation of powers is a valid doctrine and a presumption of legislative regularity is its proper corollary, this court should reserve the right of review to ensure the General Assembly’s compliance with constitutional mandates.’ ” Caulkins, 2023 IL 129453, ¶ 95 (quoting Dunigan, 165 Ill. 2d at 257-58 ). ¶ 62 In Caulkins, Justice Holder White, in a dissent that I joined, also recognized that since Dunigan this court has noted the legislature has “ ‘shown remarkably poor self discipline in policing itself in regard to the three-readings requirement.’ ” Id. ¶ 96 (quoting Friends of the Pa

2025In Geja’s Cafe, 153 Ill. 2d at 260 , this court declined the invitation to abandon the enrolled-bill doctrine, feeling ‘the doctrine of separation of powers is more compelling.’ However, this court deferred to the legislature ‘hesitantly’ and ‘reserve[d] the right to revisit this issue on another day to decide the continued propriety of ignoring this constitutional violation.’ Id. *** Accuracy Firearms [also] addressed the serious concerns raised by the plaintiffs there as to the legislature’s repeated failure to adhere to the requirements of article IV, section 8(d), and the three-readings ru

2025While separation of powers is a valid doctrine and a presumption of legislative regularity is its proper corollary, this court should reserve the right of review to ensure the General Assembly’s compliance with constitutional mandates.’ ” Caulkins, 2023 IL 129453, ¶ 95 (quoting Dunigan, 165 Ill. 2d at 257-58 ). ¶ 62 In Caulkins, Justice Holder White, in a dissent that I joined, also recognized that since Dunigan this court has noted the legislature has “ ‘shown remarkably poor self discipline in policing itself in regard to the three-readings requirement.’ ” Id. ¶ 96 (quoting Friends of the Pa

2025While separation of powers is a valid doctrine and a presumption of legislative regularity is its proper corollary, this court should reserve the right of review to ensure the General Assembly’s compliance with constitutional mandates.’ ” Caulkins, 2023 IL 129453, ¶ 95 (quoting Dunigan, 165 Ill. 2d at 257-58 ). ¶ 62 In Caulkins, Justice Holder White, in a dissent that I joined, also recognized that since Dunigan this court has noted the legislature has “ ‘shown remarkably poor self discipline in policing itself in regard to the three-readings requirement.’ ” Id. ¶ 96 (quoting Friends of the Pa

2025While separation of powers is a valid doctrine and a presumption of legislative regularity is its proper corollary, this court should reserve the right of review to ensure the General Assembly’s compliance with constitutional mandates.’ ” Caulkins, 2023 IL 129453, ¶ 95 (quoting Dunigan, 165 Ill. 2d at 257-58 ). ¶ 62 In Caulkins, Justice Holder White, in a dissent that I joined, also recognized that since Dunigan this court has noted the legislature has “ ‘shown remarkably poor self discipline in policing itself in regard to the three-readings requirement.’ ” Id. ¶ 96 (quoting Friends of the Pa

2023While separation of powers is a valid doctrine and a presumption of legislative regularity is its proper corollary, this court should reserve the right of review to ensure the General Assembly’s compliance with constitutional mandates.” Id. at 257-58. ¶ 96 Since that case, this court has noted the legislature has “shown remarkably poor self-discipline in policing itself in regard to the three-readings requirement.” Friends of the Parks, 203 Ill. 2d at 329 (citing Geja’s Cafe v. Metropolitan Pier & Exposition Authority, 153 Ill. 2d 239, 260 (1992) (noting that “ignoring the three- readings requ

2020In Giebelhausen v. Daley, 407 Ill. 25, 48 (1950), our supreme court held that the “complete substitution of a new bill under the original number, dealing with a subject which was not akin or closely allied to the original bill, and which was not read three times in each House, after it has been so altered, [was a] clear violation of” a similar three-readings rule in the 1870 Constitution.

1995The State concedes that the bill was thereafter amended prior to enactment, but argues that amendments that are "germane" to the general subject matter of the bill are exempted from the three-readings requirement. ( Giebelhausen v. Daley (1950), 407 Ill. 25, 46-47 , 95 N.E.2d 84 .) The State argues that both the amendment and the original bill sought to revise the Criminal Code and, thus, the amendment was germane to the subject matter of the bill.

2025App. 3d 974, 992 (2006), Doe v. Lyft, Inc., 2020 IL App (1st) 191328 , ¶¶ 51-55, Accuracy Firearms, LLC v. Pritzker, 2023 IL App (5th) 230035, ¶¶ 36-46 , First Midwest Bank v. Rossi, 2023 IL App (4th) 220643, ¶¶ 220-41 , and Rowe v. Raoul, 2023 IL 129248, ¶ 8 (noting the plaintiffs raised a three-readings rule claim in the circuit court)). ¶ 63 Because I continue to wholeheartedly agree with the dissenting opinion in Caulkins, I restate its compelling analysis here: “In Friends of the Parks, 203 Ill. 2d at 329 , this court noted it is ‘ever mindful of its duty to enforce the constitution of th

2023App. 3d 974, 992 (2006); Doe v. Lyft, Inc., 2020 IL App (1st) 191328, ¶¶ 51-55 ; Accuracy Firearms, LLC v. Pritzker, 2023 IL App (5th) 230035, ¶¶ 36-46 ; First Midwest Bank v. Rossi, 2023 IL App (4th) 220643 , - 24 - ¶¶ 220-41; Rowe v. Raoul, 2023 IL 129248, ¶ 8 (noting the plaintiffs raised a three- readings rule claim in the circuit court 1). ¶ 97 In Friends of the Parks, 203 Ill. 2d at 329 , this court noted it is “ever mindful of its duty to enforce the constitution of this state” and “urge[d] the legislature to follow the three-readings rule.” The court went on to state that, “[w]hile sep

2025See also Schwegmann Brothers v. Calvert Distillers Corp., 341 U.S. 384, 396 (1951) (Jackson, J., concurring, joined by Minton, J.) (noting the three-readings requirement is intended ‘to make sure that each House knows what it is passing and passes what it wants’).

2023See also Schwegmann Brothers v. Calvert Distillers Corp., 341 U.S. 384, 396 (1951) (Jackson, J., concurring, joined by Minton, J.) (noting the three-readings requirement is intended “to make sure that each House knows what it is passing and passes what it wants”).

2025App. 3d 974, 992 (2006), Doe v. Lyft, Inc., 2020 IL App (1st) 191328 , ¶¶ 51-55, Accuracy Firearms, LLC v. Pritzker, 2023 IL App (5th) 230035, ¶¶ 36-46 , First Midwest Bank v. Rossi, 2023 IL App (4th) 220643, ¶¶ 220-41 , and Rowe v. Raoul, 2023 IL 129248, ¶ 8 (noting the plaintiffs raised a three-readings rule claim in the circuit court)). ¶ 63 Because I continue to wholeheartedly agree with the dissenting opinion in Caulkins, I restate its compelling analysis here: “In Friends of the Parks, 203 Ill. 2d at 329 , this court noted it is ‘ever mindful of its duty to enforce the constitution of th

2023App. 3d 974, 992 (2006); Doe v. Lyft, Inc., 2020 IL App (1st) 191328, ¶¶ 51-55 ; Accuracy Firearms, LLC v. Pritzker, 2023 IL App (5th) 230035, ¶¶ 36-46 ; First Midwest Bank v. Rossi, 2023 IL App (4th) 220643 , - 24 - ¶¶ 220-41; Rowe v. Raoul, 2023 IL 129248, ¶ 8 (noting the plaintiffs raised a three- readings rule claim in the circuit court 1). ¶ 97 In Friends of the Parks, 203 Ill. 2d at 329 , this court noted it is “ever mindful of its duty to enforce the constitution of this state” and “urge[d] the legislature to follow the three-readings rule.” The court went on to state that, “[w]hile sep

2025While separation of powers is a valid doctrine and a presumption of legislative regularity is its proper corollary, this court should reserve the right of review to ensure the General Assembly’s compliance with constitutional mandates.’ ” Caulkins, 2023 IL 129453, ¶ 95 (quoting Dunigan, 165 Ill. 2d at 257-58 ). ¶ 62 In Caulkins, Justice Holder White, in a dissent that I joined, also recognized that since Dunigan this court has noted the legislature has “ ‘shown remarkably poor self discipline in policing itself in regard to the three-readings requirement.’ ” Id. ¶ 96 (quoting Friends of the Pa

2025On the contrary, the practice of gutting and replacing legislation ‘discourages public confidence and participation,’ ‘deprives the public of notice,’ and ‘is antithetical to the intent of the three readings requirement.’ League of Women Voters, 499 P.3d at 405 .” Caulkins, 2023 IL 129453, ¶ 109 . ¶ 68 In this case, the landlord-tenant bill that received votes on three different days in the House in February 2023 was in no way the venue bill that passed the House on one vote in May 2023.

2020Although the court recognized that one purpose of the Transportation Network Providers Act is to ensure the safety of ridesharing passengers, the court found that section 25(e)’s exemption of ridesharing companies from common carrier status is rationally related to the Act’s additional goal of “promot[ing] and enabl[ing] the growth of TNCs in the state of Illinois.” Quoting Illinois Transportation Trade Ass’n v. City of Chicago, 839 F.3d 594, 599 (7th Cir. 2016), the court explained that it is “permissible for a government to choose ‘the side of deregulation, and thus of competition,’ when it

2020Although the court recognized that one purpose of the Transportation Network Providers Act is to ensure the safety of ridesharing passengers, the court found that section 25(e)’s exemption of ridesharing companies from common carrier status is rationally related to the Act’s additional goal of “promot[ing] and enabl[ing] the growth of TNCs in the state of Illinois.” Quoting Illinois Transportation Trade Ass’n v. City of Chicago, 839 F.3d 594, 599 (7th Cir. 2016), the court explained that it is “permissible for a government to choose ‘the side of deregulation, and thus of competition[,]’ when i

2025The Caulkins dissent also noted “[t]hat lack of legislative self-discipline continues to this day.” Id. (citing Orr v. - 24 - Edgar, 298 Ill.

2025See id. ¶ 103; Dunigan, 165 Ill. 2d at 258 ; see also Board of Education of Richland School District No. 88A v. City of Crest Hill, 2021 IL 126444, ¶ 5 (“ ‘Illinois courts often take judicial notice of facts that are readily verifiable for referring to sources of indisputable accuracy’ such as court records or public documents, including records on [a] government website” (quoting People v. Johnson, 2021 IL 125738, ¶ 54 )). ¶ 65 In this case, as noted by the circuit court, House Bill 3062 (HB 3062) (103d Ill.

2025See, e.g., Yakich v. Aulds, 2019 IL 123667, ¶ 13 .

2025See id. ¶ 103; Dunigan, 165 Ill. 2d at 258 ; see also Board of Education of Richland School District No. 88A v. City of Crest Hill, 2021 IL 126444, ¶ 5 (“ ‘Illinois courts often take judicial notice of facts that are readily verifiable for referring to sources of indisputable accuracy’ such as court records or public documents, including records on [a] government website” (quoting People v. Johnson, 2021 IL 125738, ¶ 54 )). ¶ 65 In this case, as noted by the circuit court, House Bill 3062 (HB 3062) (103d Ill.

2024See, e.g., Stanphill v. Ortberg, 2020 IL App (2d) 190769, ¶ 9 (application of interest under section 2-1303 is mandatory; trial court has no discretion to refrain from imposing interest on money judgment). ¶ 79 Three-Readings Rule ¶ 80 Advocate argues that the General Assembly violated the Illinois Constitution’s three- readings requirement.