Illinois Compiled Statutes
745 ILCS 10/4-102 (2026)
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 is provided, for failure to provide adequate police protection or service, failure to prevent the commission of crimes, failure to detect or solve crimes, and failure to identify or apprehend criminals
✓ current as of May 2026
Find cases:
SyfertCases citing this section
IL-ILGAilga.gov
JustiaChapter on Justia
CornellLII Search
CasesGoogle Scholar
(745 ILCS 10/4-102)
(from Ch. 85, par. 4-102)
Sec. 4-102.
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 is provided, for
failure to provide adequate police protection or service, failure to
prevent the commission of crimes, failure to detect or solve crimes,
and failure to identify or apprehend criminals.
This immunity is not waived by a contract for private security service,
but cannot be transferred to any non-public entity or employee.
(Source: P.A. 84-1431.)
Notes of Decisions
Cited in 76
cases (20 in the last 5 years), 1993–2026 · leading case: DeSMET EX REL. v. Cnty. of Rock Island, 848 N.E.2d 1030 (Ill. 2006).
DeSMET EX REL. v. Cnty. of Rock Island, 848 N.E.2d 1030 (Ill. 2006). “Although the defendants raised the applicability of several sections of the Act, all specifically argued they were immune from liability under the provisions of section 4-102 of the Act (745 ILCS 10/4-102 (West 2002)). After a hearing, the circuit court dismissed plaintiff's…”
Moore v. Green, 848 N.E.2d 1015 (Ill. 2006). “Chaiten and David Pressman, Chicago, for amici curiae Illinois Coalition Against Domestic Violence et al. Justice FITZGERALD delivered the judgment of the court: The sole issue in this case is whether the absolute immunity provided by section 4-102 or 4-107 of the Local…”
Hernandez v. Kirksey, 715 N.E.2d 669 (Ill. App. Ct. 1999). “On appeal, plaintiffs contend that the trial court erred in finding that defendants' conduct was immunized under section 4-102 of the Local Governmental and Governmental Employees Tort Immunity Act (Tort Immunity Act) (745 ILCS 10/4-102 (West 1996)). Count II of plaintiffs'…”
United States v. Christopher Duguay, 93 F.3d 346 (7th Cir. 1996). “The police do not owe a duty to the general public to remove vulnerable automobiles from high-crime neighborhoods.”
Wisnasky v. CSX Transp., Inc., 2020 IL App (5th) 170418 (Ill. App. Ct. 2020). “Whether, assuming all well pled facts of Plaintiff’s Second Amended Complaint (incorrectly titled ‘Complaint at Law’) are true, [Vandalia] is entitled to absolute immunity on the counts brought against [it] under one or more of the following provisions of the Local Governmental…”
Schultz v. St. Clair Cnty., 2022 IL 126856 (Ill. 2022). “OPINION ¶1 In this case we are asked to consider whether the absolute immunity provided by section 4-102 of the Local Governmental and Governmental Employees Tort Immunity Act (Tort Immunity Act) (745 ILCS 10/4-102 (West 2016)) or the limited immunity provided by section 15.”
Brooks v. McLean Cnty. Dist. Unit No. 5, 2014 IL App (4th) 130503 (Ill. App. Ct. 2014). “trial court erred in (1) applying the public-duty rule instead of engaging in a traditional duty analysis, (2) finding the complaint failed to plead sufficient facts to establish willful and wanton misconduct, and (3) holding the complaint was barred by sections 4-102, 2-201,…”
Prough v. Madison Cnty., 2013 IL App (5th) 110146 (Ill. App. Ct. 2013). “” 745 ILCS 10/4-102 (West 2010). “[S]ection 4-102 of the Tort Immunity Act codifies the separate common law rule that municipalities or their employees are not liable for failure to supply police or fire protection.”
Payne v. The City of Chicago, 2014 IL App (1st) 123010 (Ill. App. Ct. 2014). “The issue presented for review is whether the trial court erred when it granted summary judgment for the defendant based on its immunity under section 4-102 of the Illinois Local Governmental and Governmental Employees Tort Immunity Act for providing police protection or service…”
Mack Indus., Ltd. v. The Vill. of Dolton, 2015 IL App (1st) 133620 (Ill. App. Ct. 2015). “¶ 68 In their motion to dismiss, defendants cited three sections of the Tort Immunity Act: (1) section 2-104, concerning the issuance, denial, suspension or revocation of permits (745 ILCS 10/2-104 (West 2012)); (2) section 4-102, concerning police protection (745 ILCS 10/4-102…”
Floyd Ex Rel. Floyd v. Rockford Park Dist., 823 N.E.2d 1004 (Ill. App. Ct. 2005). “Defendants moved to dismiss the second amended complaint, contending that they did not owe plaintiff a duty to protect him from Washington's intentional act and that they were immune from liability pursuant to section 3-108 of the Act and section 4-102 of the Act (745 ILCS…”
Glover v. City of Chicago, 2023 IL App (1st) 211353 (Ill. App. Ct. 2023). “Specifically, defendants maintained that the officers were immune under sections 4-102 and 4-107 (745 ILCS 10/4-102, 4-107 (West 2020)) and the City, as their employer, was immune under section 2-109 (id.”
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.
|