ILCS » Chapter 745 · Act 10
Illinois Compiled Statutes

745 ILCS 10/2-102 (2026)

Notwithstanding any other provision of law, a local public entity is not liable to pay punitive or exemplary damages in any action brought directly or indirectly against it by the injured party or a third party

✓ current as of May 2026
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(745 ILCS 10/2-102) (from Ch. 85, par. 2-102)
    Sec. 2-102. Notwithstanding any other provision of law, a local public entity is not liable to pay punitive or exemplary damages in any action brought directly or indirectly against it by the injured party or a third party. In addition, no public official is liable to pay punitive or exemplary damages in any action arising out of an act or omission made by the public official while serving in an official executive, legislative, quasi-legislative or quasi-judicial capacity, brought directly or indirectly against him by the injured party or a third party.
(Source: P.A. 84-1431.)

    
Notes of Decisions
Cited in 32 cases (11 in the last 5 years), 1996–2025 · leading case: Doe Ex Rel. Doe v. White, 627 F. Supp. 2d 905 (C.D. Ill. 2009).
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Doe Ex Rel. Doe v. White, 627 F. Supp. 2d 905 (C.D. Ill. 2009). · cites it 3× “Plaintiffs object, however, to the dismissal of punitive damages against Defendant Heidbreder (the Assistant Principal), on the grounds that 745 ILCS 10/2-102 does not provide “blanket immunity” for employees of public entities.”
Sablik v. Cnty. of De Kalb, 2019 IL App (2d) 190293 (Ill. App. Ct. 2021). · cites it 3× “The County appealed, arguing that the section 3-602 damages were punitive damages and that, because section 2-102 of the Tort Immunity Act (745 ILCS 10/2-102 (West 1992)) shields local public entities from liability for punitive damages, the trial court erred in trebling the…”
In re Marriage of Murray, 2014 IL App (2d) 121253 (Ill. App. Ct. 2014). · cites it 5× “¶2 The Conservation District moved for dismissal, arguing that the statutory penalty is tantamount to a punitive award, which is barred by section 2-102 of the Local Governmental and Governmental Employees Tort Immunity Act (Tort Immunity Act) (745 ILCS 10/2-102 (West 2012)).…”
S.J. Ex Rel. S.J. v. Perspectives Charter Sch., 685 F. Supp. 2d 847 (N.D. Ill. 2010). · cites it 2× “See 745 ILCS 10/2-102 (“Notwithstanding any other provision of law, a local public entity is not liable to pay punitive or exemplary damages in any action brought directly or indirectly against it by the injured party or a third party.”
In re Marriage of Murray, 2014 IL App (2d) 121253 (Ill. App. Ct. 2014). · cites it 5× “¶2 The Conservation District moved for dismissal, arguing that the statutory penalty is tantamount to a punitive award, which is barred by section 2-102 of the Local Governmental and Governmental Employees Tort Immunity Act (Tort Immunity Act) (745 ILCS 10/2-102 (West 2012)).…”
Doe 20 v. Bd. of Educ. of the Cmty. Unit Sch. Dist. No. 5, 680 F. Supp. 2d 957 (C.D. Ill. 2010). “Motion to Strike The School District moves to strike the punitive damages sought against it. The School District is a “local public entity” immune from punitive damages.”
Doe v. Hinsdale Twp. High Sch. Dist. 86, 905 N.E.2d 343 (Ill. App. Ct. 2009). · cites it 2× “The county claimed that section 3-602 was a punitive-damages provision and was therefore inapplicable, because section 2-102 of the Tort Immunity Act (745 ILCS 10/2-102 (West 1994)) prohibited the assessment of punitive damages against a governmental entity.”
Davis v. City of Chicago, 2020 IL App (1st) 182551-U (Ill. App. Ct. 2020). “3 The City appeals, arguing that the $2 million award for emotional distress also should be remitted because it is outside the range of fair and reasonable compensation, resulted from passion or prejudice, shocks the judicial conscience, and is barred by the prohibition in…”
Lifton v. Bd. of Educ. of City of Chicago, 290 F. Supp. 2d 940 (N.D. Ill. 2003). “Meuer cites 745 ILCS 10/2-102, which states that “no public official is liable to pay punitive or exemplary damages in any action arising out of an act or omission made by the public official while serving in an official executive, legislative, quasi-legislative or…”
In re Marriage of Solomon, 2015 IL App (1st) 133048 (Ill. App. Ct. 2015). “1-13-3048 ¶ 21 Provident argues, for the first time on appeal, that the trial court properly denied Iren's petition because section 2-102 of the Local Governmental and Governmental Employees Tort Immunity Act (Tort Immunity Act) (745 ILCS 10/2-102 (West 2010)) grants Provident…”
Martinez v. Cook Cnty. Sheriff's Off., 2017 IL App (3d) 160514 (Ill. App. Ct. 2018). · cites it 2× “plaint, alleging that plaintiff was not entitled to the money judgment requested because (1) the failure to withhold maintenance was the result of an innocent mistake on the part of one of defendants’ employees and was not knowingly done and (2) the claim for a money judgment…”
Reno v. Newport Twp., 2018 IL App (2d) 170967 (Ill. App. Ct. 2018). “rty-tax-objection case for which the sole and exclusive remedy was provided in article 23 of the Property Tax Code; (3) the levy was not a "new rate" within the meaning of section 18-190(a) of PTELL; and (4) plaintiff's request for punitive damages and attorney fees in count IV…”
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