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Illinois Compiled Statutes

745 ILCS 10/2-106 (2026)

A local public entity is not liable for an injury caused by an oral promise or misrepresentation of its employee, whether or not such promise or misrepresentation is negligent or intentional

✓ current as of May 2026
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(745 ILCS 10/2-106) (from Ch. 85, par. 2-106)
    Sec. 2-106. A local public entity is not liable for an injury caused by an oral promise or misrepresentation of its employee, whether or not such promise or misrepresentation is negligent or intentional.
(Source: Laws 1965, p. 2983.)

    
Notes of Decisions
Cited in 13 cases (2 in the last 5 years), 1999–2026 · 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× “) 745 ILCS 10/2-106 ( West 1998 ). And section 2-109 provides that a local public entity is not liable where its employee is not liable.”
Doe-3 v. McLean Cnty. Unit Dist. No. 5 Bd. of Directors, 2012 IL 112479 (Ill. 2012). “¶ 90 While section 2-106 is concerned with public entities and addresses only oral, not written, misrepresentations, it is still persuasive evidence that the legislature intended for the immunity to cover both negligent and willful and wanton misrepresentations.”
DeSMET EX REL. v. Cnty. of Rock Island, 848 N.E.2d 1030 (Ill. 2006). “Various defendants also relied on the public duty rule, as well as sections 2-106, 2-109, 2-201, 2-204, 2-210, 2-212, 3-108, and 5-101 of the Tort Immunity Act (745 ILCS 10/2-106, 2-109, 2-201, 2-204, 2-210, 2-212, 3-108, 5-101 (West 2002)), and section 3.”
Henrich v. Libertyville High Sch., 712 N.E.2d 298 (Ill. 1999). “745 ILCS 10/2-106 (West 1994). Section 3-108(a) of the Act immunizes a local public entity or a public employee from liability for an injury caused by a failure to supervise an activity on, or a failure to supervise the use of, any public property.”
Lyons Twp. ex rel Kielczynski v. Vill. of Indian Head Park, 2017 IL App (1st) 161574 (Ill. App. Ct. 2017). · cites it 3× “On appeal, relator contends the circuit court erred in finding that his claims were barred by the Act’s public disclosure provision and that the Village was immune from liability based on section 2-106 of the Illinois Local Governmental and Governmental Employees Tort Immunity…”
Lyons Twp. ex rel Kielczynski v. Vill. of Indian Head Park, 2017 IL App (1st) 161574 (Ill. App. Ct. 2017). · cites it 3× “On appeal, relator contends the circuit court erred in finding that his claims were barred by the Act’s public disclosure provision and that the Village was immune from liability based on section 2-106 of the Illinois Local Governmental and Governmental 1-16-1574 Employees Tort…”
People v. Gutierrez, 2024 IL App (2d) 230260 (Ill. App. Ct. 2024). “There, the appellate court construed section 2-106 of the Local Governmental and Governmental Employees Tort Immunity Act (745 ILCS 10/2-106 (West 2014)), which stated: “ ‘[A] local public entity is not liable for an injury caused by an oral promise or misrepresentation of its…”
AR Ex Rel. MR v. Chicago Bd. of Educ., 724 N.E.2d 6 (Ill. App. Ct. 1999). “" We do not believe the titling of Article IV as "Police and Correctional Activities" demonstrates a legislative intent to limit application of section 4-102 to public entities strictly charged with law enforcement duties.”
Lyons Twp. ex rel Kielczynski v. Vill. of Indian Head Park, 2017 IL App (1st) 161574 (Ill. App. Ct. 2017). · cites it 3× “On appeal, relator contends the circuit court erred in finding that his claims were barred by the Act’s public disclosure provision and that the Village was immune from liability based on section 2-106 of the Illinois Local Governmental and Governmental 1-16-1574 Employees Tort…”
John's Pro-Tree Serv., Inc. v. Vill. of Dolton, 2026 IL App (1st) 250027-U (Ill. App. Ct. 2026). · cites it 2× “1-25-0027 Village’s combined motion to dismiss improperly comingled grounds for dismissal under sections 2-615 and 2-619 of the Code of Civil Procedure (735 ILCS 5/2-615, 2-619 (West 2024)) (the Code); (2) the Village was not immune under section 2-106 of the Local Governmental…”
Pouk v. Vill. of Romeoville (Ill. App. Ct. 2010). “2d 140, 145 (2007); 745 ILCS 10/2-106 (West 2006). Section 2-202 immunizes public employees for an act or omission "in the execution or enforcement of any law unless such act or omission constitutes willful and wanton conduct.”
O'Malley v. Vill. of Palos Park (Ill. App. Ct. 2004). “The court noted that section 2-106 of the Tort Immunity Act provides that a "local public entity is not liable for an injury caused by an oral promise or misrepresentation of its employee, whether or not such promise or misrepresentation is negligent or intentional.”
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