licensure requirement in Illinois

2015I know of no supreme court case interpreting the licensure requirement of section 2-202, but Sarkissian’s pronouncement that “strict compliance with statutes governing service of process on public entities is required” (Sarkissian, 201 Ill. 2d at 109 ) appears in principle to apply also to requirements for service on private corporations, including the licensure mandate of section 2-202. ¶ 36 I would hope, however, that today’s result would give pause to those who have the authority to forestall such outcomes in the future.

2014I know of no supreme court case interpreting the licensure requirement of section 2-202, but Sarkissian’s pronouncement that “strict compliance with statutes governing service of process on public entities is required” (Sarkissian, 201 Ill. 2d at 109 ) appears in principle to apply also to requirements for service on private corporations, including the licensure mandate of section 2-202. ¶ 36 I would hope, however, that today’s result would give pause to those who have the authority to forestall such outcomes in the future.

2004As our supreme court has made clear, “We expressly reaffirm the license requirement of Dolan and its progeny and decline plaintiffs invitation to deviate therefrom.” Sullivan, 209 Ill. 2d at 123 ; accord Jones, 154 Ill. 2d at 43-44 ; Purtill, 111 Ill. 2d at 244 ; Dolan, 77 Ill. 2d at 285 .

2004As our supreme court has made clear, "We expressly reaffirm the license requirement of Dolan and its progeny and decline plaintiff's invitation to deviate therefrom." Sullivan, 209 Ill.2d at 123 , 282 Ill.Dec. 348 , 806 N.E.2d 645 , accord Jones, 154 Ill.2d at 43-44 , 180 Ill.Dec. 330 , 607 N.E.2d 224 ; Purtill, 111 Ill.2d at 244 , 95 Ill.Dec. 305 , 489 N.E.2d 867 ; Dolan, 77 Ill.2d at 285 , 32 Ill.Dec. 900 , 396 N.E.2d 13 .

2004As our supreme court has made clear, “We expressly reaffirm the license requirement of Dolan and its progeny and decline plaintiffs invitation to deviate therefrom.” Sullivan, 209 Ill. 2d at 123 ; accord Jones, 154 Ill. 2d at 43-44 ; Purtill, 111 Ill. 2d at 244 ; Dolan, 77 Ill. 2d at 285 .

2004As our supreme court has made clear, "We expressly reaffirm the license requirement of Dolan and its progeny and decline plaintiff's invitation to deviate therefrom." Sullivan, 209 Ill.2d at 123 , 282 Ill.Dec. 348 , 806 N.E.2d 645 , accord Jones, 154 Ill.2d at 43-44 , 180 Ill.Dec. 330 , 607 N.E.2d 224 ; Purtill, 111 Ill.2d at 244 , 95 Ill.Dec. 305 , 489 N.E.2d 867 ; Dolan, 77 Ill.2d at 285 , 32 Ill.Dec. 900 , 396 N.E.2d 13 .

2022However, as noted above, “[t]he purpose of a summary judgment proceeding is not to try an issue of fact, but to determine whether any genuine issue of material fact exists.” Happel, 199 Ill. 2d at 186 . ¶ 35 We cannot find that Granite City’s right to summary judgment was “clear and free from doubt.” Whether any of defendant’s four properties fell within the licensure requirement based on the defining language in municipal ordinance 5.142.010 is a material fact in the ultimate determination of whether defendant violated the ordinance by not having the license.

2019In contrast to Craigmiles, for the reasons outlined above, the dual-license prohibition is not a naked attempt to protect licensed operators but rather is a conceivable method to prevent vertical integration and promote competition in the video gaming industry as well as a conceivable method to promote self-regulation. ¶ 56 Lastly, in Merrifield, 547 F.3d at 981-82 , a California law required non-pesticide pest controllers of animals such as bats, raccoon, skunks, and squirrels to be licensed, but exempted from the licensure requirement non-pesticide pest controllers of animals such as mice, r