ILCS » Chapter 745 · Act 10
Illinois Compiled Statutes

745 ILCS 10/2-104 (2026)

A local public entity is not liable for an injury caused by the issuance, denial, suspension or revocation of, or by the failure or refusal to issue, deny, suspend or revoke, any permit, license, certificate, approval, order or similar authorization where the entity or its employee is authorized by enactment to determine whether or not such authorization should be issued, denied, suspended or revoked

✓ current as of May 2026
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(745 ILCS 10/2-104) (from Ch. 85, par. 2-104)
    Sec. 2-104. A local public entity is not liable for an injury caused by the issuance, denial, suspension or revocation of, or by the failure or refusal to issue, deny, suspend or revoke, any permit, license, certificate, approval, order or similar authorization where the entity or its employee is authorized by enactment to determine whether or not such authorization should be issued, denied, suspended or revoked.
(Source: Laws 1965, p. 2983.)

    
Notes of Decisions
Cited in 19 cases (3 in the last 5 years), 2001–2022 · 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× “" 745 ILCS 10/2-104 ( West 1998 ). The Village's denial of CDG's rezoning petition is precisely what the legislature intended to immunize such entities from.”
Mack Indus., Ltd. v. The Vill. of Dolton, 2015 IL App (1st) 133620 (Ill. App. Ct. 2015). · cites it 5× “The Village also contended count III of Mack's verified complaint must be dismissed pursuant to section 2-619 of the Code, arguing the Village is immune from liability for failing to issue permits or certificates, pursuant to section 2- 104 of the Tort Immunity Act (745 ILCS…”
Vill. of Itasca v. Vill. of Lisle, 817 N.E.2d 160 (Ill. App. Ct. 2004). · cites it 2× “745 ILCS 10/2-104 (West 2002). However, plaintiff alleges that Lisle acted outside its statutory authority in approving the rebate agreement.”
Mack Indus., Ltd. v. Vill. of Dolton, 2015 IL App (1st) 133620 (Ill. App. Ct. 2015). · cites it 5× “The Village also contended count III of Mack’s verified complaint must be dismissed pursuant to section 2-619 of the Code, arguing the Village is immune from liability for failing to issue permits or certificates, pursuant to section 2-104 of the Tort Immunity Act (745 ILCS…”
Salvi v. The Vill. of Lake Zurich, 2016 IL App (2d) 150249 (Ill. App. Ct. 2016). “See 745 ILCS 10/2-104 (entities), 2-206 (employees) (West 2014).”
MacH Mold Inc. v. Clover Assocs., Inc., 383 F. Supp. 2d 1015 (N.D. Ill. 2005). “The plain language of section 2-104 states that a “local public entity is not liable for an injury caused by the issuance, denial, suspension, or revocation of, or by the failure or refusal to issue, deny, suspend, or revoke, any permit, license, certificate, approval, order, or…”
Williams v. Miracle Ctr., Inc., 2022 IL App (1st) 210291 (Ill. App. Ct. 2022). “, 745 ILCS 10/2-104 (West 2020) (providing tort immunity for the local public entity whose function is to issue, deny, suspend, or revoke any permit, license, or similar authorization); id.”
Fam. Life Church v. City of Elgin, 561 F. Supp. 2d 978 (N.D. Ill. 2008). “In relevant part that statute reads (745 ILCS 10/2-104): A local public entity is not liable for an injury caused by the issuance, denial, suspension or revocation of, or by the failure or refusal to issue, deny, suspend or revoke, any permit, license, certificate, approval,…”
Xochi, LLC v. City of Galena, 2022 IL App (4th) 220340 (Ill. App. Ct. 2022). · cites it 3× “The trial court granted that motion, finding that (1) section 2-104 of the Local Governmental and Governmental Employees Tort Immunity Act (Act) (745 ILCS 10/2-104 (West 2020)) shielded Galena from liability and (2) Xochi failed to state a prima facie case for negligence.”
Salvi v. Vill. of Lake Zurich, 2016 IL App (2d) 150249 (Ill. App. Ct. 2017). “¶ 45 Sections 2-104 and 2-206 of the Tort Immunity Act grant immunity to local public entities and public employees for injuries caused by the issuance, denial, suspension, or revocation of, or by the failure or refusal to issue, deny, suspend, or revoke any permit, license,…”
Sorrells v. City of Macomb, 2015 IL App (3d) 140763 (Ill. App. Ct. 2015). “The City also argued that it was immune from liability under section 2-104 of the Local Governmental and Governmental Employees Tort Immunity Act (Illinois Tort Immunity Act) (745 ILCS 10/2-104 (West 2012)) (providing immunity to a local public entity for issuing a permit,…”
Bowler v. City of Chicago, 876 N.E.2d 140 (Ill. App. Ct. 2007). “" 745 ILCS 10/2-104 (West 2006). Pursuant to section 2-105, a local public entity is not liable for an injury caused by "its failure to make an inspection, or by reason of making an inadequate or negligent inspection, of any property, other than its own, to determine whether the…”
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