ILCS » Chapter 745 · Act 10
Illinois Compiled Statutes

745 ILCS 10/2-105 (2026)

A local public entity is not liable for 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 property complies with or violates any enactment or contains or constitutes a hazard to health or safety

✓ current as of May 2026
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(745 ILCS 10/2-105) (from Ch. 85, par. 2-105)
    Sec. 2-105. A local public entity is not liable for 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 property complies with or violates any enactment or contains or constitutes a hazard to health or safety.
(Source: Laws 1965, p. 2983.)

    
Notes of Decisions
Cited in 16 cases (1 in the last 5 years), 1997–2022 · leading case: Williams v. Miracle Ctr., Inc., 2022 IL App (1st) 210291 (Ill. App. Ct. 2022).
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Williams v. Miracle Ctr., Inc., 2022 IL App (1st) 210291 (Ill. App. Ct. 2022). · cites it 4× “1-21-0291 prior to its use but that they were immune under section 2-105 of the Local Governmental and Governmental Employees Tort Immunity Act (Tort Immunity Act) (745 ILCS 10/2-105 (West 2020)). Section 2-105 provides: “A local public entity is not liable for injury caused by…”
Ware v. City of Chicago, 873 N.E.2d 944 (Ill. App. Ct. 2007). · cites it 2× “Moreover, section 2-207 of the Tort Immunity Act provides: "A public employee is not liable for an injury caused by his failure to make an inspection, or by reason of making an inadequate or negligent inspection, of any property, other than that of the local public entity…”
Nourse v. The City of Chicago, 2017 IL App (1st) 160664 (Ill. App. Ct. 2017). · cites it 2× “” 745 ILCS 10/2-105 (West 2014). ¶ 19 Section 2-207 contains the same protections for employees of public entities, stating: “A public employee is not liable for an injury caused by his failure to make an inspection, or by reason of making an inadequate or negligent inspection,…”
Nourse v. The City of Chicago, 2017 IL App (1st) 160664 (Ill. App. Ct. 2017). · cites it 3× “The suit was dismissed, with prejudice, on the ground that it was barred by sections 2-105 and 2-207 of the Local Governmental and Governmental Employees Tort Immunity Act (Act) (745 ILCS 10/2-105, 2-207 (West 2014)), which provide certain protections to public entities from…”
Suchy v. The City of Geneva, 2014 IL App (2d) 130367 (Ill. App. Ct. 2014). “”)) and (b) section 2-105 of the Tort Immunity Act (745 ILCS 10/2-105 (West 2012) (“A local public entity is not liable for 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…”
Union Pac. R.R. v. Vill. of South Barrington, 958 F. Supp. 1285 (N.D. Ill. 1997). “Accordingly, based on the court’s analysis in Barnett and the holding in Glenn , the Board members are entitled to immunity under 745 ILCS 10/2-105 for all state law claims against them, regardless of their motivation in enacting the Amending Ordinance.”
Grabinski v. Forest Preserve Dist., 2020 IL App (1st) 191267 (Ill. App. Ct. 2020). “The Forest Preserve’s supplement also raised three governmental tort immunities: (1) no liability for failure to inspect the property of others (745 ILCS 10/2-105 (West 2016)), (2) no liability for the effects of weather on roadways (745 ILCS 10/3-105(a) (West 2016)), and (3) no…”
Sorrells v. City of Macomb, 2015 IL App (3d) 140763 (Ill. App. Ct. 2015). “e 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 10/2-105 (West 2006). Under the plain and unambiguous language of these sections, it would appear that the City is immune from liability for failing to enforce the building code, issuing the construction permit, negligently inspecting and/or failing to inspect the…”
Sorrells v. City of Macomb, 2015 IL App (3d) 140763 (Ill. App. Ct. 2016). “e 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,…”
Ries v. City of Chicago, 950 N.E.2d 631 (Ill. 2011). “Sections 2-105 and 2-207 do not contain exceptions for willful and wanton misconduct, and thus the plaintiffs could not rely on section 2-202's exception for willful and wanton misconduct when sections 2-105 and 2-207 were applicable.”
Alexander v. Consumers Illinois Water Co. (Ill. App. Ct. 2005). “745 ILCS 10/2-105 (West 2005) Consumers argues that the Village has waived its reliance on the Tort Immunity Act because it did not file its reliance on the act as an affirmative defense in its answer to Consumer’s counter claim.”
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