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Illinois Compiled Statutes

5 ILCS 430/15-10 (2026)

Protected activity

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(5 ILCS 430/15-10)
    Sec. 15-10. Protected activity. An officer, a member, a State employee, or a State agency shall not take any retaliatory action against a State employee because the State employee does any of the following:
        (1) Discloses or threatens to disclose to a
    
supervisor or to a public body an activity, policy, or practice of any officer, member, State agency, or other State employee that the State employee reasonably believes is in violation of a law, rule, or regulation.
        (2) Provides information to or testifies before any
    
public body conducting an investigation, hearing, or inquiry into any violation of a law, rule, or regulation by any officer, member, State agency, or other State employee.
        (3) Assists or participates in a proceeding to
    
enforce the provisions of this Act.
(Source: P.A. 93-615, eff. 11-19-03; 93-617, eff. 12-9-03.)

    
Notes of Decisions
Cited in 19 cases (9 in the last 5 years), 2013–2023 · leading case: Mullins v. Evans, 2021 IL App (1st) 191962, 187 N.E.3d 178.
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Mullins v. Evans, 2021 IL App (1st) 191962, 187 N.E.3d 178. · cites it 4× “See 5 ILCS 430/15-10 (West 2018). However, nothing in the Ethics Act suggests that an employee is afforded a protectable property interest in continued employment due to the provisions of the statute, and we cannot create such a property interest.”
Crowley v. Watson, 2016 IL App (1st) 142847, 51 N.E.3d 69. · cites it 3× “5 ILCS 430/15-10 (West 2008); see also 5 ILCS 430/1-5, 15-5 (West Supp.”
Patrick Cage v. Tiffany Harper, 42 F.4th 734 (7th Cir. 2022). · cites it 2× “” 5 ILCS 430/15-10(1) (emphasis added). Cage contends that he engaged in protected activity—re- porting the alleged conflict of interest and Bylaws violation relating to Board member Paul Vallas—only then to lose his job.”
Lugg v. Sutton, 368 F. Supp. 3d 1257 (C.D. Ill. 2019). · cites it 5× “In Count I of her Complaint, she alleges Sutton retaliated against her in violation of the Illinois Ethics Act ("Ethics Act"), 5 ILCS 430/15-10, after she complained of age and gender discrimination and assisted with a Title IX sexual misconduct claim.”
Wynn v. Illinois Dep't of Human Servs., 2017 IL App (1st) 160344, 81 N.E.3d 28. · cites it 2× “” 5 ILCS 430/15-10(1) (West 2014). ¶ 33 DHS defended that non-renewal of a fixed-term contract did not constitute a retaliatory action under the Ethics Act.”
Block v. Off. of the Illinois Sec'y of State, 2013 IL App (5th) 120157, 988 N.E.2d 718. “5 ILCS 430/15-10 (West 2006). ¶4 The Ethics Act provides for remedies for its violation.”
Mullins v. Evans, 2021 IL App (1st) 191962, 187 N.E.3d 178. · cites it 4× “See 5 ILCS 430/15-10 (West 2018). However, nothing in the Ethics Act suggests that an employee is afforded a protectable property interest in continued employment due to the provisions of the statute, and we cannot create such a property interest.”
Wynn v. Illinois Dep't of Human Servs., 2017 IL App (1st) 160344. “5 ILCS 430/15-10(1) (West 2014). “Retaliatory action” is defined as “reprimand, discharge, suspension, demotion, denial of promotion or transfer, or change in the terms or conditions of employment of any State employee, that is taken in retaliation for a State employee’s…”
Tomas v. State, No. 1:07-cv-04542 (N.D. Ill. Mar. 27, 2018). · cites it 2× “Plaintiff Tomas also moves for summary judgment in her favor, arguing that the undisputed facts when viewed with an adverse inference demonstrate that she is entitled to summary judgment on Count VIII for retaliation in violation of the Illinois Ethics Act, 5 ILCS 430/15-10, et…”
Cage v. Harper, No. 1:17-cv-07621 (N.D. Ill. July 16, 2021). · cites it 2× “See 5 ILCS 430/15-10 (note that Article 15 is entitled “Whistle Blower Protection”).”
In re M.R., 2023 IL App (1st) 231059-U. “argued that the Whistleblower Act (5 ILCS 430/15-10 (West 2022)) applied to this case in that Child Link, performing work on behalf of a state agency, retaliated against him, another state “employee” for reporting legitimate concerns about the welfare of M.”
Marion v. Governors State Univ., 2020 IL App (3d) 180423-U. “) 5 ILCS 430/15-10(1) (West 2010). A violation of section 15-10 may only be established upon a finding that (1) the State employee engaged in conduct described in section 15-10 and (2) that conduct was a contributing factor in the retaliatory action alleged by the State employee.”
Show all 19 citing cases →
5 ILCS 430/15-10(1): 11 cases
Patrick Cage v. Tiffany Harper, 42 F.4th 734 (7th Cir. 2022). “” 5 ILCS 430/15-10(1) (emphasis added). Cage contends that he engaged in protected activity—re- porting the alleged conflict of interest and Bylaws violation relating to Board member Paul Vallas—only then to lose his job.”
Wynn v. Illinois Dep't of Human Servs., 2017 IL App (1st) 160344, 81 N.E.3d 28. “” 5 ILCS 430/15-10(1) (West 2014). ¶ 33 DHS defended that non-renewal of a fixed-term contract did not constitute a retaliatory action under the Ethics Act.”
Mullins v. Evans, 2021 IL App (1st) 191962, 187 N.E.3d 178. “See 5 ILCS 430/15-10 (West 2018). However, nothing in the Ethics Act suggests that an employee is afforded a protectable property interest in continued employment due to the provisions of the statute, and we cannot create such a property interest.”
Crowley v. Watson, 2016 IL App (1st) 142847, 51 N.E.3d 69. “5 ILCS 430/15-10 (West 2008); see also 5 ILCS 430/1-5, 15-5 (West Supp.”
Wynn v. Illinois Dep't of Human Servs., 2017 IL App (1st) 160344. “5 ILCS 430/15-10(1) (West 2014). “Retaliatory action” is defined as “reprimand, discharge, suspension, demotion, denial of promotion or transfer, or change in the terms or conditions of employment of any State employee, that is taken in retaliation for a State employee’s…”
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