Illinois Compiled Statutes
745 ILCS 10/1-204 (2026)
"Injury" means death, injury to a person, or damage to or loss of property
✓ current as of May 2026
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(745 ILCS 10/1-204)
(from Ch. 85, par. 1-204)
Sec. 1-204.
"Injury" means death, injury to a person, or damage to or loss
of property. It includes any other injury that a person may suffer to his
person, reputation, character or estate which does not result from
circumstances in which a privilege is otherwise conferred by law and which
is of such a nature that it would be actionable if inflicted by a private
person. "Injury" includes any injury alleged in a civil action, whether based upon the
Constitution of the United States or the Constitution of the State of
Illinois, and the statutes or common law of Illinois or of the United States.
(Source: P.A. 84-1431.)
Notes of Decisions
Cited in 10
cases, 1994–2018 · leading case: Rozsavolgyi v. The City of Aurora, 2017 IL 121048 (Ill. 2017).
Rozsavolgyi v. The City of Aurora, 2017 IL 121048 (Ill. 2017). “See 745 ILCS 10/1-204 (West 2014) (providing that the Act's immunities apply to injuries alleged in any "civil action," including those based upon the federal or state constitutions or upon a federal or state statute).”
Rozsavolgyi v. The City of Aurora, 2016 IL App (2d) 150493 (Ill. App. Ct. 2016). “) 745 ILCS 10/1-204 (West 2014). ¶ 104 The supreme court has rejected the claim that the Tort Immunity Act “categorically excludes” nontort actions.”
Prorok v. Winnebago Cnty., 2017 IL App (2d) 161032 (Ill. App. Ct. 2017). “745 ILCS 10/1-204 (West 2016). That is a matter on which reasonable people could certainly disagree.”
Fam. Life Church v. City of Elgin, 561 F. Supp. 2d 978 (N.D. Ill. 2008). “Stl 2), Elgin is of course a “local public entity” (see 745 ILCS 10/1-206), and the harm that it asserts fits the expansive statutory definition of “injury” (745 ILCS 10/1-204). And of course Family Life’s Permit is a “permit.”
Rozsavolgyi v. City of Aurora, 2016 IL App (2d) 150493 (Ill. App. Ct. 2016). “) 745 ILCS 10/1-204 (West 2014); see also 745 ILCS 10/8-101(c) (West 2014) (one-year statute of limitations for a “civil action” under the Tort Immunity Act; “civil action” includes an action based upon the “Constitution of this State”).”
Medley v. Turner, 869 F. Supp. 567 (N.D. Ill. 1994). “Under the Illinois Local Governmental and Governmental Employees Tort Immunity Act, 745 ILCS 10/1-204, local governmental employees such as the CPD defendants may not be held liable for the acts or omissions of any other person.”
Valfer v. Evanston Nw. Healthcare, 2015 IL App (1st) 142284 (Ill. App. Ct. 2015). “" 745 ILCS 10/1-204 (West 2012). There is no such definition in the Act.”
Valfer v. Evanston Nw. Healthcare, 2015 IL App (1st) 142284 (Ill. App. Ct. 2015). “” 745 ILCS 10/1-204 (West 2012). There is no such definition in the Act.”
Prorok v. Winnebago Cnty., 2017 IL App (2d) 161032 (Ill. App. Ct. 2018). “745 ILCS 10/1-204 (West 2016). ¶9 We determine that Prorok’s claim for back pay falls outside the scope of the Tort Immunity Act, under the plain language of sections 2-101 and 1-204.”
Yang v. City of Chicago, 29 F. Supp. 2d 480 (N.D. Ill. 1998). “” 745 ILCS 10/1-204 (1997). The City strongly asserts that these definitions, especially when coupled with the Illinois common law distinction between damages and the recovery of attorneys’ fees and costs, requires this Court to follow the American Rule and not automatically…”
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