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Illinois Compiled Statutes

745 ILCS 10/2-101 (2026)

Nothing in this Act affects the right to obtain relief other than damages against a local public entity or public employee

✓ current as of May 2026
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(745 ILCS 10/2-101) (from Ch. 85, par. 2-101)
    (Text of Section before amendment by P.A. 104-457)
    Sec. 2-101. Nothing in this Act affects the right to obtain relief other than damages against a local public entity or public employee. Nothing in this Act affects the liability, if any, of a local public entity or public employee, based on:
    a contract;
    b operation as a common carrier; and this Act does not apply to any entity organized under or subject to the "Metropolitan Transit Authority Act", approved April 12, 1945, as amended;
    c The "Workers' Compensation Act", approved July 9, 1951, as heretofore or hereafter amended;
    d The "Workers' Occupational Diseases Act", approved July 9, 1951, as heretofore or hereafter amended;
    e Section 1-4-7 of the "Illinois Municipal Code", approved May 29, 1961, as heretofore or hereafter amended.
    f The "Illinois Uniform Conviction Information Act", enacted by the 85th General Assembly, as heretofore or hereafter amended.
(Source: P.A. 85-922.)
 
    (Text of Section after amendment by P.A. 104-457)
    Sec. 2-101. Nothing in this Act affects the right to obtain relief other than damages against a local public entity or public employee. Nothing in this Act affects the liability, if any, of a local public entity or public employee, based on:
    a contract;
    b operation as a common carrier; and this Act does not apply to any entity organized under or subject to the Chicago Transit Authority Act;
    c The "Workers' Compensation Act", approved July 9, 1951, as heretofore or hereafter amended;
    d The "Workers' Occupational Diseases Act", approved July 9, 1951, as heretofore or hereafter amended;
    e Section 1-4-7 of the "Illinois Municipal Code", approved May 29, 1961, as heretofore or hereafter amended.
    f The "Illinois Uniform Conviction Information Act", enacted by the 85th General Assembly, as heretofore or hereafter amended.
(Source: P.A. 104-457, eff. 6-1-26.)

    
Notes of Decisions
Cited in 61 cases (7 in the last 5 years), 1996–2026 · leading case: Vill. of Bloomingdale v. CDG Enter., Inc., 752 N.E.2d 1090 (Ill. 2001).
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Vill. of Bloomingdale v. CDG Enter., Inc., 752 N.E.2d 1090 (Ill. 2001). · cites it 5× “Second, whether a claim for quasi-contract is proper under section 2-101(a) of the Act (745 ILCS 10/2-101(a) (West 1998)) and whether the counterplaintiff alleged sufficient facts for this court to impose a quasicontract remedy.”
Rozsavolgyi v. The City of Aurora, 2017 IL 121048 (Ill. 2017). · cites it 2× “See 745 ILCS 10/2-101 (West 2016) ("Nothing in this Act affects the right to obtain relief other than damages against a local public entity or public employee.”
Moore v. Green, 848 N.E.2d 1015 (Ill. 2006). · cites it 2× “2d 69 , citing 745 ILCS 10/2-101 (West 2002). According to the appellate court, section 2-101 of the Tort Immunity Act does not provide an exhaustive list of exemptions, and the "the strongly worded language of the legislature in enacting the Domestic Violence Act" cannot be…”
Krywin v. Chicago Transit Auth., 938 N.E.2d 440 (Ill. 2010). “745 ILCS 10/2-101(b) (West 2008). The legislature has also codified the rule with respect to private citizens arising from their negligent attempts to remove ice and snow from sidewalks adjoining their residences in the Snow Removal Act.”
Van Meter v. Darien Park Dist., 799 N.E.2d 273 (Ill. 2003). “The plaintiffs have won this battle, but they will ultimately lose the war.”
Harinek v. 161 North Clark Street Ltd. P'ship, 692 N.E.2d 1177 (Ill. 1998). “Both the Partnership and the City moved to dismiss the complaint under section 2-615 of the Code of Civil Procedure (735 ILCS 5/2-615 (West 1994)). The circuit court denied the Partnership's motion to dismiss count I, but granted the City's motion to dismiss counts II and III…”
Salvi v. The Vill. of Lake Zurich, 2016 IL App (2d) 150249 (Ill. App. Ct. 2016). · cites it 2× “¶ 27 Section 2-101 of the Tort Immunity Act (745 ILCS 10/2-101 (West 2014)) clarifies the kinds of claims to which its immunity applies.”
Ballinger v. City of Danville, Illinois, 2012 IL App (4th) 110637 (Ill. App. Ct. 2012). · cites it 3× “¶ 18 Likewise, since plaintiff’s lien-invalidity claim seeks only a declaration, it is an action that seeks “relief other than damages,” as set forth in the first sentence of section 2-101 of the Immunity Act (745 ILCS 10/2-101 (West 2008)) and thus is excluded from the Immunity…”
United Airlines, Inc. v. City of Chicago, 954 N.E.2d 710 (Ill. App. Ct. 2011). · cites it 2× “" 745 ILCS 10/8-101(a), (c) (West 2010). ¶ 8 Initially, we note that, on its face, section 8-101 applies to "any" civil action such that its one-year statute of limitations seemingly would apply to either a tort action or a breach of contract action against the City.”
Gassman v. The Clerk of the Circuit Court of Cook Cnty., 2017 IL App (1st) 151738 (Ill. App. Ct. 2017). “745 ILCS 10/2-101 (West 2014). Here, Gassman does not seek damages; he merely seeks a refund of certain fees that were improperly collected under section 27(a)(g) of the Act.”
Smith v. Waukegan Park Dist., 896 N.E.2d 232 (Ill. 2008). “Therefore, section 4(h) plainly prohibits a retaliatory discharge for the exercise of workers' compensation rights. This conclusion is further buttressed by the legislature's declaration in section 2-101(c) of the Tort Immunity Act that "[n]othing in this Act affects the…”
Ballinger v. City of Danville, 966 N.E.2d 594 (Ill. App. Ct. 2012). · cites it 3× “*599 ¶ 18 Likewise, since plaintiff's lien-invalidity claim seeks only a declaration, it is an action that seeks "relief other than damages," as set forth in the first sentence of section 2-101 of the Immunity Act (745 ILCS 10/2-101 (West 2008)) and thus is excluded from the…”
Show all 61 citing cases →
— 745 ILCS 10/2-101(a) — 13 cases
Vill. of Bloomingdale v. CDG Enter., Inc., 752 N.E.2d 1090 (Ill. 2001). “Second, whether a claim for quasi-contract is proper under section 2-101(a) of the Act (745 ILCS 10/2-101(a) (West 1998)) and whether the counterplaintiff alleged sufficient facts for this court to impose a quasicontract remedy.”
Salvi v. The Vill. of Lake Zurich, 2016 IL App (2d) 150249 (Ill. App. Ct. 2016). “¶ 27 Section 2-101 of the Tort Immunity Act (745 ILCS 10/2-101 (West 2014)) clarifies the kinds of claims to which its immunity applies.”
Am. Fam. Mut. Ins. Co. v. Tyler, 2016 IL App (1st) 153502 (Ill. App. Ct. 2016).
United Airlines, Inc. v. City of Chicago, 954 N.E.2d 710 (Ill. App. Ct. 2011). “" 745 ILCS 10/8-101(a), (c) (West 2010). ¶ 8 Initially, we note that, on its face, section 8-101 applies to "any" civil action such that its one-year statute of limitations seemingly would apply to either a tort action or a breach of contract action against the City.”
Lyons Twp. ex rel Kielczynski v. Vill. of Indian Head Park, 2017 IL App (1st) 161574 (Ill. App. Ct. 2017).
— 745 ILCS 10/2-101(b) — 1 case
Krywin v. Chicago Transit Auth., 938 N.E.2d 440 (Ill. 2010). “745 ILCS 10/2-101(b) (West 2008). The legislature has also codified the rule with respect to private citizens arising from their negligent attempts to remove ice and snow from sidewalks adjoining their residences in the Snow Removal Act.”
— 745 ILCS 10/2-101(c) — 5 cases
Smith v. Waukegan Park Dist., 896 N.E.2d 232 (Ill. 2008). “Therefore, section 4(h) plainly prohibits a retaliatory discharge for the exercise of workers' compensation rights. This conclusion is further buttressed by the legislature's declaration in section 2-101(c) of the Tort Immunity Act that "[n]othing in this Act affects the…”
Ballinger v. City of Danville, Illinois, 2012 IL App (4th) 110637 (Ill. App. Ct. 2012). “¶ 18 Likewise, since plaintiff’s lien-invalidity claim seeks only a declaration, it is an action that seeks “relief other than damages,” as set forth in the first sentence of section 2-101 of the Immunity Act (745 ILCS 10/2-101 (West 2008)) and thus is excluded from the Immunity…”
Ballinger v. City of Danville, 966 N.E.2d 594 (Ill. App. Ct. 2012). “*599 ¶ 18 Likewise, since plaintiff's lien-invalidity claim seeks only a declaration, it is an action that seeks "relief other than damages," as set forth in the first sentence of section 2-101 of the Immunity Act (745 ILCS 10/2-101 (West 2008)) and thus is excluded from the…”
Collins v. Town of Normal, 951 N.E.2d 1285 (Ill. App. Ct. 2011).
Collins v. Bartlett Park Dist., 2013 IL App (2d) 130006 (Ill. App. Ct. 2013).
— 745 ILCS 10/2-101(e) — 5 cases
Ballinger v. City of Danville, Illinois, 2012 IL App (4th) 110637 (Ill. App. Ct. 2012). “¶ 18 Likewise, since plaintiff’s lien-invalidity claim seeks only a declaration, it is an action that seeks “relief other than damages,” as set forth in the first sentence of section 2-101 of the Immunity Act (745 ILCS 10/2-101 (West 2008)) and thus is excluded from the Immunity…”
Ballinger v. City of Danville, 966 N.E.2d 594 (Ill. App. Ct. 2012). “*599 ¶ 18 Likewise, since plaintiff's lien-invalidity claim seeks only a declaration, it is an action that seeks "relief other than damages," as set forth in the first sentence of section 2-101 of the Immunity Act (745 ILCS 10/2-101 (West 2008)) and thus is excluded from the…”
Madison v. The City of Chicago, 2017 IL App (1st) 160195 (Ill. App. Ct. 2017).
Madison v. City of Chicago, 2017 IL App (1st) 160195 (Ill. App. Ct. 2017).
City of Geneso v. Pyrotem Props., LLC, 2022 IL App (4th) 220206-U (Ill. App. Ct. 2022).
— 745 ILCS 10/2-101(f) — 1 case
Rozsavolgyi v. City of Aurora, 2016 IL App (2d) 150493 (Ill. App. Ct. 2016).
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