Illinois Compiled Statutes
745 ILCS 10/2-206 (2026)
A public employee is not liable for an injury caused by his issuance, denial, suspension or revocation of or by his failure or refusal to issue, deny, suspend or revoke, any permit, license, certificate, approval, order or similar authorization where he 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 10/2-206)
(from Ch. 85, par. 2-206)
Sec. 2-206.
A public employee is not liable for an injury caused by his
issuance, denial, suspension or revocation of or by his failure or refusal
to issue, deny, suspend or revoke, any permit, license, certificate,
approval, order or similar authorization where he 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 7
cases (1 in the last 5 years), 2003–2023 · leading case: Mack Indus., Ltd. v. Vill. of Dolton, 2015 IL App (1st) 133620 (Ill. App. Ct. 2015).
Mack Indus., Ltd. v. Vill. of Dolton, 2015 IL App (1st) 133620 (Ill. App. Ct. 2015). “” 745 ILCS 10/2-206 (West 2010).7 Section 4-102 of the Tort Immunity Act provides in part: “Neither a local public entity nor a public employee is liable for failure to establish a police department or otherwise provide police protection service or, if police protection service…”
Mack Indus., Ltd. v. The Vill. of Dolton, 2015 IL App (1st) 133620 (Ill. App. Ct. 2015). “¶ 72 In addition to the above-quoted sections, the majority holds that defendants can raise, for the first time on appeal, a statutory section that they did not cite before the trial court, namely, section 2-206 (745 ILCS 10/2-206 (West 2012)). Supra ¶ 37 n.”
Clarage v. Kuzma, 795 N.E.2d 348 (Ill. App. Ct. 2003). “" 745 ILCS 10/2-206 (West 2002). Scully argues that the section applies to his conduct because Clarage was seeking the approval of the Deer Creek Township for the resort.”
Vill. of Riverdale v. Nosmo Kings, 2023 IL App (1st) 221380 (Ill. App. Ct. 2023). “The Officials answered the third-party complaint and raised several affirmative defenses, including that the claims were barred by statutes of limitations, the doctrine of laches, and sections 2-206, 2-207, and 2-212 of the Tort Immunity Act (“Immunity Act”) (745 ILCS 10/2-206,…”
Salvi v. Vill. of Lake Zurich, 2016 IL App (2d) 150249 (Ill. App. Ct. 2017). “See 745 ILCS 10/2-104 ( West 2014 ) (entities); 745 ILCS 10/2-206 ( West 2014 ) (employees).”
Mack Indus., Ltd. v. The Vill. of Dolton, 2015 IL App (1st) 133620 (Ill. App. Ct. 2015). “¶ 72 In addition to the above-quoted sections, the majority holds that defendants can raise, for the first time on appeal, a statutory section that they did not cite before the trial court, namely, section 2-206 (745 ILCS 10/2-206 (West 2010)). Supra ¶ 37 n.”
Clarage v. Kuzma (Ill. App. Ct. 2003). “” 745 ILCS 10/2-206 (West 2002). Scully argues that the section applies to his conduct because Clarage was seeking the approval of the Deer Creek Township for the resort.”
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