ILCS » Chapter 745 · Act 10
Illinois Compiled Statutes

745 ILCS 10/2-103 (2026)

A local public entity is not liable for an injury caused by adopting or failing to adopt an enactment or by failing to enforce any law

✓ current as of May 2026
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(745 ILCS 10/2-103) (from Ch. 85, par. 2-103)
    Sec. 2-103. A local public entity is not liable for an injury caused by adopting or failing to adopt an enactment or by failing to enforce any law.
(Source: Laws 1965, p. 2983.)

    
Notes of Decisions
Cited in 49 cases (12 in the last 5 years), 1997–2026 · leading case: Rozsavolgyi v. The City of Aurora, 2017 IL 121048 (Ill. 2017).
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Rozsavolgyi v. The City of Aurora, 2017 IL 121048 (Ill. 2017). · cites it 2× “" 745 ILCS 10/2-103 (West 2014). ¶ 6 Rozsavolgyi filed a motion to strike the City's amended affirmative defenses, and the City filed a motion for a Rule 308(a) finding.”
Vill. of Bloomingdale v. CDG Enter., Inc., 752 N.E.2d 1090 (Ill. 2001). · cites it 2× “It asserted sovereign immunity based on various provisions of the Tort Immunity Act (see 745 ILCS 10/2-103, 2-104, 2-106, 2-109, 2-201, 2-205 (West 1998)).”
Strauss v. City of Chicago, 2021 IL App (1st) 191977 (Ill. App. Ct. 2021). · cites it 2× “The circuit court found that defendant was immune from these claims under sections 2-103 and 2-201 of the Tort Immunity Act (745 ILCS 10/2-103, 2-201 (West 2016)). Here, plaintiff contends that those sections do not immunize conduct that occurred before the B2-2 zoning ordinance…”
Salvi v. The Vill. of Lake Zurich, 2016 IL App (2d) 150249 (Ill. App. Ct. 2016). · cites it 2× “The Village cited sections 2-103, 2-104, 2-202, and 3-105 of the Tort Immunity Act (745 ILCS 10/2-103, 2-104, 2-202, 3-105 (West 2014)).”
Dyson v. City of Calumet City, 306 F. Supp. 3d 1028 (E.D. Ill. 2018). “The Seventh Circuit recently accepted a concession (and cited supporting authority) that, while Illinois provides a procedure in which individuals could obtain compensation for physical takings, it does not have a similar procedure for regulatory takings.”
Callahan v. City of Chicago, 813 F.3d 658 (7th Cir. 2016). “See 745 ILCS 10/2-103; Sorrells v. Macomb, 2015 IL App (3d) 140763 ¶¶ 25-26 , 398 Ill.”
Bezanis v. Fox Waterway Agency, 2012 IL App (2d) 100948 (Ill. App. Ct. 2012). · cites it 2× “, the Sheriff had engaged in a course of action that showed an actual or deliberate intention to cause harm or an utter indifference to or conscious disregard for the safety of others; and (3) plaintiff had failed to allege sufficient facts to show that the Sheriff owed…”
Vill. of Itasca v. Vill. of Lisle, 817 N.E.2d 160 (Ill. App. Ct. 2004). “Defendants argue that Lisle should be immune under section 2-103 of the Local Governmental and Governmental Employees Tort Immunity Act (Tort Immunity Act) (745 ILCS 10/2-103 (West 2002)), which provides that a local government entity is immune from injury caused by its failure…”
Weiler v. Vill. of Oak Lawn, 86 F. Supp. 3d 874 (N.D. Ill. 2015). “Thus, Weiler’s state law claims against the Village are barred to the extent that they contemplate liability based on the Board members’ votes.”
Sciarrone v. Vill. of Island Lake, Illinois, 2025 IL App (2d) 240153 (Ill. App. Ct. 2025). · cites it 5× “” 745 ILCS 10/2-103 (West 2018). In similar terms, public employees (which includes officers and board members) (id.”
Salvi v. Vill. of Lake Zurich, 2016 IL App (2d) 150249 (Ill. App. Ct. 2017). · cites it 2× “The Village cited sections 2-103, 2-104, 2-202, and 3-105 of the Tort Immunity Act (745 ILCS 10/2-103, 2-104, 2-202, 3-105 (West 2014)).”
Bowler v. City of Chicago, 876 N.E.2d 140 (Ill. App. Ct. 2007). · cites it 2× “The City filed a motion to dismiss the second amended complaint pursuant to section 2-619(a)(9) of the Illinois Code of Civil Procedure (Code) (735 ILCS 5/2-619(a)(9) (West 2006)), arguing that it was immune from liability under sections 2-103, 2-205, 2-104 and 2-105 of the Tort…”
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