futility exception (Illinois) · Go Syfert
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futility exception in Illinois

13 Illinois opinions name it 2 courts 1989–2020 0 in the last five years

The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
cluster 579986green
ca7 · 1992 · cited in 2 Illinois opinions naming this issue, 2019–2019
2 sentences

2019In the Seventh Circuit, the futility exception requires plaintiffs to show “ ‘that it is certain that their claim will be denied on appeal, 15 No. 1-18-1646 not merely that they doubt an appeal will result in a different decision.’ ” Citadel Securities, LLC v. Chicago Board Options Exchange, Inc., 808 F.3d 694, 700 (7th Cir. 2015) (quoting Smith v. Blue Cross & Blue Shield United of Wisconsin, 959 F.2d 655, 659 (7th Cir.1992)). ¶ 69 The fact that the Board members adjudicating plaintiffs’ cases were appointed by one of the parties to the administrative proceeding, the Sheriff, certainly leaves

2019In the Seventh Circuit, the futility exception requires plaintiffs to show “ ‘that it is certain that their claim will be denied on appeal, not merely that they doubt an appeal will result in a different decision.’ ” Citadel Securities, LLC v. Chicago Board Options Exchange, Inc., 808 F.3d 694, 700 (7th Cir. 2015) (quoting Smith v. Blue Cross & Blue Shield United of Wisconsin, 959 F.2d 655, 659 (7th Cir. 1992)). ¶ 69 The fact that the Board members adjudicating plaintiffs’ cases were appointed by one of the parties to the administrative proceeding, the Sheriff, certainly leaves open the possib

22
Citadel Securities, LLC v. Chicago Board Options Exchange, Inc.green
ca7 · 2015 · cited in 2 Illinois opinions naming this issue, 2019–2019
2 sentences

2019In the Seventh Circuit, the futility exception requires plaintiffs to show “ ‘that it is certain that their claim will be denied on appeal, 15 No. 1-18-1646 not merely that they doubt an appeal will result in a different decision.’ ” Citadel Securities, LLC v. Chicago Board Options Exchange, Inc., 808 F.3d 694, 700 (7th Cir. 2015) (quoting Smith v. Blue Cross & Blue Shield United of Wisconsin, 959 F.2d 655, 659 (7th Cir.1992)). ¶ 69 The fact that the Board members adjudicating plaintiffs’ cases were appointed by one of the parties to the administrative proceeding, the Sheriff, certainly leaves

2019In the Seventh Circuit, the futility exception requires plaintiffs to show “ ‘that it is certain that their claim will be denied on appeal, not merely that they doubt an appeal will result in a different decision.’ ” Citadel Securities, LLC v. Chicago Board Options Exchange, Inc., 808 F.3d 694, 700 (7th Cir. 2015) (quoting Smith v. Blue Cross & Blue Shield United of Wisconsin, 959 F.2d 655, 659 (7th Cir. 1992)). ¶ 69 The fact that the Board members adjudicating plaintiffs’ cases were appointed by one of the parties to the administrative proceeding, the Sheriff, certainly leaves open the possib

22
Cullen v. Town Council of the Lincolngreen
ri · 2004 · cited in 2 Illinois opinions naming this issue, 2008–2008
2 sentences

2008See, e.g., Cullen v. Town Council, 850 A.2d 900, 906 (R.I.2004); Coleman v. Newburgh Enlarged City School District, 319 F.Supp.2d 446, 450 (S.D.N.Y.2004); Rann v. Chao, 154 F.Supp.2d 61, 65 (D.D.C. 2001).

2008See, e.g., Cullen v. Town Council, 850 A.2d 900, 906 (R.I. 2004); Coleman v. Newburgh Enlarged City School District, 319 F. Supp. 2d 446, 450 (S.D.N.Y. 2004); Rann v. Chao, 154 F. Supp. 2d 61, 65 (D.D.C. 2001).

22
Rann v. Chaogreen
dcd · 2001 · cited in 2 Illinois opinions naming this issue, 2008–2008
2 sentences

2008See, e.g., Cullen v. Town Council, 850 A.2d 900, 906 (R.I.2004); Coleman v. Newburgh Enlarged City School District, 319 F.Supp.2d 446, 450 (S.D.N.Y.2004); Rann v. Chao, 154 F.Supp.2d 61, 65 (D.D.C. 2001).

2008See, e.g., Cullen v. Town Council, 850 A.2d 900, 906 (R.I. 2004); Coleman v. Newburgh Enlarged City School District, 319 F. Supp. 2d 446, 450 (S.D.N.Y. 2004); Rann v. Chao, 154 F. Supp. 2d 61, 65 (D.D.C. 2001).

22
Coleman v. Newburgh Enlarged City School Districtgreen
nysd · 2004 · cited in 2 Illinois opinions naming this issue, 2008–2008
2 sentences

2008See, e.g., Cullen v. Town Council, 850 A.2d 900, 906 (R.I.2004); Coleman v. Newburgh Enlarged City School District, 319 F.Supp.2d 446, 450 (S.D.N.Y.2004); Rann v. Chao, 154 F.Supp.2d 61, 65 (D.D.C. 2001).

2008See, e.g., Cullen v. Town Council, 850 A.2d 900, 906 (R.I. 2004); Coleman v. Newburgh Enlarged City School District, 319 F. Supp. 2d 446, 450 (S.D.N.Y. 2004); Rann v. Chao, 154 F. Supp. 2d 61, 65 (D.D.C. 2001).

22
Traff v. Fabrogreen
illappct · 1949 · cited in 2 Illinois opinions naming this issue, 2005–2005
2 sentences

2005Contrary to plaintiff's contention, those denials do not establish "an existing standard" or practice by which the Director denies such motions "as a matter of course." See Traff v. Fabro , 337 Ill.

2005Contrary to plaintiffs contention, those denials do not establish “an existing standard” or practice by which the Director denies such motions “as a matter of course.” See Traff v. Fabro, 337 Ill.

22
Kawaoka v. City of Arroyo Grandegreen
ca9 · 1994 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020See Kawaoka v. City of Arroyo Grande, 17 F.3d 1227, 1232 (9th Cir. 1994) (the futility exception does not alter a party’s obligation to file at least one meaningful development proposal); Freeman v. United States, 875 F.3d 623, 628 (Fed.

11
Freeman v. United Statesgreen
cafc · 2017 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020See Kawaoka v. City of Arroyo Grande, 17 F.3d 1227, 1232 (9th Cir. 1994) (the futility exception does not alter a party’s obligation to file at least one meaningful development proposal); Freeman v. United States, 875 F.3d 623, 628 (Fed.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Castaneda v. Illinois Human Rights Commission green
ill · 1989
2 sentences

2019And as we’ve said, they rely not on the facial-challenge exception to the exhaustion bar but on the futility exception. ¶ 64 “An aggrieved party may seek judicial review of an administrative decision without complying with the exhaustion of remedies doctrine *** where the agency cannot provide an adequate remedy or where it is patently futile to seek relief before the agency.” Castaneda, 132 Ill. 2d at 308–09.

2019Instead, they again raise what we call the futility exception, albeit a slight variation on it, where the exhaustion requirement is waived because the administrative action “cannot provide an adequate remedy.” Castaneda, 132 Ill. 2d at 308–09. ¶ 78 We see this claim differently than the other due process claims.

31990–2019
Dock Club, Inc. v. Illinois Liquor Control Commission green
illappct · 1980
2 sentences

1992Dock Club, Inc. v. Illinois Liquor Control Comm’n (1980), 83 Ill.

1992The court observed that to adopt the plaintiff’s theories “would be to condone a race to the courthouse and to undermine severely the authority of the [administrative agency], a result quite clearly not intended by the legislature.” 83 Ill.

31991–1992
Northwestern University v. City of Evanston green
ill · 1978
2 sentences

1992(Northwestern University v. City of Evanston (1978), 74 Ill. 2d 80 , 383 N.E.2d 964 .) The futility doctrine, as it is sometimes called, is limited to the factual situation presented on a case-by-case basis.

1992(Northwestern University v. City of Evanston (1978), 74 Ill. 2d 80 , 383 N.E.2d 964 .) The futility doctrine, as it is sometimes called, is limited to the factual situation presented on a case-by-case basis.

31989–1992
Canel v. Topinka green
ill · 2004
2 sentences

2008In support of its conclusion that the futility exception does apply here, the majority relies on Canel v. Topinka, 212 Ill.2d 311 , 288 Ill.Dec. 623 , 818 N.E.2d 311 (2004), which held that the plaintiff was exempted from exhausting administrative remedies because to do so would have been futile.

2008In support of its conclusion that the futility exception does apply here, the majority relies on Canel v. Topinka, 212 Ill. 2d 311 (2004), which held that the plaintiff was exempted from exhausting administrative remedies because to do so would have been futile.

22008–2008
Beahringer v. Page green
ill · 2003
2 sentences

2008The majority rejects Beahringer v. Page, 204 Ill.2d 363 , 273 Ill.Dec. 784 , 789 N.E.2d 1216 (2003), as support for defendants' argument that the futility exception does not apply in this case.

2008The majority rejects Beahringer v. Page, 204 Ill. 2d 363 (2003), as support for defendants’ argument that the futility exception does not apply in this case.

22008–2008
Constantine v. Village of Glen Ellyn green
illappct · 1991
1 sentence

1993(Constantine v. Village of Glen Ellyn (1991), 217 Ill.

11993–1993
Castaneda v. Human Rights Commission green
illappct · 1988
1 sentence

1989App. 3d at 1087 .) The court also held that plaintiff’s petition did not fit into the futility exception because parties aggrieved by administrative rulings cannot avoid the exhaustion requirement merely because the relief they seek before an agency may be, or even probably will be, denied. 175 Ill.

11989–1989

Statutes the citing opinions construe

IL § 735 ILCS 5/2-619 (4) IL § 735 ILCS 5/3-101 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 116 (1974–2026) TX 29 (1995–2025) PA 17 (1917–2020) WA 17 (1989–2026) CT 15 (1949–2020) IL 13 (1989–2020) NC 12 (2000–2025) MA 12 (1956–2026) NM 11 (1981–2022) MI 11 (1976–2021) UT 10 (2006–2024) FL 9 (1929–2021) DC 9 (1986–2026) NY 9 (2012–2022) NV 8 (2006–2021) AK 7 (1988–2022) GA 7 (2011–2017) TN 6 (1995–2013) MD 6 (2001–2025) RI 6 (2004–2026) OH 6 (2010–2025) CO 6 (2005–2026) IA 5 (1975–2016) OR 5 (1978–2025) SC 4 (2005–2017) VA 3 (2018–2025) MO 3 (1987–2020) MT 3 (2004–2006) NJ 3 (2007–2025) HI 3 (1995–2025) AR 3 (2005–2017) AL 2 (1988–2011) IN 2 (2005–2007) VT 2 (2009–2015) OK 2 (2004–2013) MS 2 (2003–2006) WI 2 (2001–2002) DE 2 (1993–1993) WY 2 (1996–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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