ILCS » Chapter 740 · Act 174
Illinois Compiled Statutes

740 ILCS 174/20 (2026)

Retaliation for certain refusals prohibited

✓ current as of May 2026
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(740 ILCS 174/20)
    Sec. 20. Retaliation for certain refusals prohibited. An employer may not take retaliatory action against an employee for refusing to participate in an activity that the employee has a good faith belief that such participation would result in a violation of a State or federal law, rule, or regulation, including, but not limited to, violations of the Freedom of Information Act.
(Source: P.A. 103-867, eff. 1-1-25.)

    
Notes of Decisions
Cited in 48 cases (14 in the last 5 years), 2007–2026 · leading case: Sardiga v. N. Trust Co., 948 N.E.2d 652 (Ill. App. Ct. 2011).
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Sardiga v. N. Trust Co., 948 N.E.2d 652 (Ill. App. Ct. 2011). · cites it 8× “ANALYSIS On appeal, Sardiga argues that the trial court erred in granting summary judgment in favor of Northern Trust on count II of his complaint, which alleged a violation of the Illinois Whistleblower Act (740 ILCS 174/20 (West 2004)).”
Young v. Alden Gardens of Waterford, LLC, 2015 IL App (1st) 131887 (Ill. App. Ct. 2015). · cites it 4× “OPINION ¶1 Defendant-appellant Alden Gardens of Waterford, LLC, appeals from the judgment entered on a jury verdict finding it liable under the Illinois Whistleblower Act (740 ILCS 174/20 (West 2010)) for retaliating against a former employee, plaintiff-appellee Bethany Young,…”
Lucas v. The Cnty. of Cook, 2013 IL App (1st) 113052 (Ill. App. Ct. 2013). · cites it 6× “Count I of her complaint alleged that Cook County violated section 20 of the Illinois Whistleblower Act (Act) (740 ILCS 174/20 (West 2010)), while count II of her complaint contained a claim for common law retaliatory discharge.”
Roberts v. Bd. of Trs. of Cmty. Coll. Dist. No. 508, 2019 IL 123594 (Ill. 2019). · cites it 4× “Count II alleged violation of section 20 of the Whistleblower Act (740 ILCS 174/20 (West 2014)). Count III sought recovery based on wrongful termination.”
Roberts v. Bd. of Trs. Cmty. Coll. Dist. No. 508, 2018 IL App (1st) 170067 (Ill. App. Ct. 2018). · cites it 4× “508 d/b/a City Colleges of Chicago, alleging causes of action for common law retaliatory discharge, violations of the Whistleblower Act ( 740 ILCS 174/20 (West 2016) ), and wrongful termination.”
Parks v. Speedy Title & Appraisal Review Servs., 318 F. Supp. 3d 1053 (E.D. Ill. 2018). “CS 174/15(a) ; • "for disclosing information to a government or law enforcement agency, where the employee has reasonable cause to believe that the information discloses a violation of a State or federal law, rule, or regulation," 740 ILCS 174/15(b) ; • "for refusing to…”
Young v. Alden Gardens of Waterford, LLC, 2015 IL App (1st) 131887 (Ill. App. Ct. 2015). · cites it 3× “The trial court denied summary judgment as to count II under section 20 of the Whistleblower Act (740 ILCS 174/20 (West 2010)) and the case proceeded to trial on that count.”
Zuccolo v. Hannah Marine Corp., 900 N.E.2d 353 (Ill. App. Ct. 2008). · cites it 2× “mployee “for disclosing information to a government or law enforcement agency, where the employee has reasonable cause to believe that the information discloses a violation of a State or federal law, rule, or regulation” (740 ILCS 174/15 (West 2004)) or “for refusing to…”
Corah v. The Bruss Co., 2017 IL App (1st) 161030 (Ill. App. Ct. 2017). · cites it 2× “740 ILCS 174/20 (West 2012). Specifically, plaintiff argued that his termination was a direct result of his refusal to file a false accident investigation report (AIR), which would have been used as a basis for Albea’s claim for benefits pursuant to the Workers’ Compensation Act.”
Ulm v. Mem'l Med. Ctr., 964 N.E.2d 632 (Ill. App. Ct. 2012). “" 740 ILCS 174/20 (West 2006). Plaintiff claims that she was retaliated against for refusing to sign certifications accompanying subpoenaed medical records stating that the record was complete and accurate and had been prepared in the course of defendant's business.”
Callahan v. Edgewater Care & Rehab. Ctr., Inc., 872 N.E.2d 551 (Ill. App. Ct. 2007). “a government or law enforcement agency, where the employee has reasonable canse to believe that the information discloses a violation of a State or federal law, rule, or regulation” (740 ILCS 174/15 (West 2004)) and from retaliating against an employee “for refusing to…”
Robinson v. Alter Barge Line, Inc., 513 F.3d 668 (7th Cir. 2008). “One ground is section 20 of the Illinois Whistle-blower Act, 740 ILCS 174/20, which forbids an employer to “retaliate against an employee for refusing to participate in an activity that would result in a violation of a State or federal law, rule, or regulation.”
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