ILCS » Chapter 745 · Act 10
Illinois Compiled Statutes

745 ILCS 10/4-106 (2026)

Neither a local public entity nor a public employee is liable for:     (a) Any injury resulting from determining to parole or release a prisoner, to revoke his or her parole or release, or the terms and conditions of his or her parole or release

✓ current as of May 2026
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(745 ILCS 10/4-106) (from Ch. 85, par. 4-106)
    Sec. 4-106. Neither a local public entity nor a public employee is liable for:
    (a) Any injury resulting from determining to parole or release a prisoner, to revoke his or her parole or release, or the terms and conditions of his or her parole or release.
    (b) Any injury inflicted by an escaped or escaping prisoner.
(Source: P.A. 98-558, eff. 1-1-14.)

    
Notes of Decisions
Cited in 16 cases (8 in the last 5 years), 2009–2023 · leading case: Robinson v. Vill. of Sauk Vill., 2022 IL 127236 (Ill. 2022).
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Robinson v. Vill. of Sauk Vill., 2022 IL 127236 (Ill. 2022). · cites it 4× “OPINION ¶1 Section 4-106(b) of the Local Governmental and Governmental Employees Tort Immunity Act (Tort Immunity Act) (745 ILCS 10/4-106(b) (West 2016)) provides local public entities and public employees with absolute immunity from liability for “[a]ny injury inflicted by an…”
Doe-3 v. McLean Cnty. Unit Dist. No. 5 Bd. of Directors, 2012 IL 112479 (Ill. 2012). “, 745 ILCS 10/4-106(b) (West 2010) (“Neither a local public entity nor a public employee is liable for: Any injury inflicted by an escaped or escaping prisoner.”
Townsend v. City of Chicago, 2019 IL App (1st) 180771 (Ill. App. Ct. 2021). · cites it 4× “” 745 ILCS 10/4-106(b) (West 2014). ¶6 The parties then engaged in discovery.”
Prough v. Madison Cnty., 2013 IL App (5th) 110146 (Ill. App. Ct. 2013). “The plaintiffs attempted to avoid application of section 4-106(b) of the Tort Immunity Act (745 ILCS 10/4-106(b) (West 2008)), immunizing a public entity for injury inflicted by an escaping prisoner, by arguing that section 4-106(b) did not cover the police officers’ conduct in…”
Robinson v. Vill. of Sauk Vill., 2021 IL App (1st) 200223 (Ill. App. Ct. 2021). “See 745 ILCS 10/4-106 (West 2016). The circuit court reasoned that, at the point in time that the police officers pointed their guns at Coffey as he sat in the black Buick in the church parking lot, he was in custody, as no reasonable person in his position would have felt free…”
Wright-Young v. Chicago State Univ., 2019 IL App (1st) 181073 (Ill. App. Ct. 2019). “Compare 745 ILCS 10/4-105 (West 2012) (no liability for the negligent failure to provide medical care to a prisoner in custody), with 745 ILCS 10/4-106(b) (West 2012) (blanket immunity for “[a]ny injury inflicted by an escaped or escaping prisoner”).”
Glover v. City of Chicago, 2023 IL App (1st) 211353 (Ill. App. Ct. 2023). “Our supreme court affirmed our reversal, holding that, based on the facts alleged, the officers in that case were immune from liability pursuant to section 4-106(b) of the Act (745 ILCS 10/4-106(b) (West 2008)), a provision which specifically immunizes public entities and their…”
Robinson v. Vill. of Sauk Vill., 2021 IL App (1st) 200223 (Ill. App. Ct. 2021). · cites it 2× “Bugajski and Vaughan asserted immunity under section 2-202 of the Tort Immunity Act (745 ILCS 10/2-202 (West 2016)), arguing that their actions did not rise to the level of willful and wanton conduct; a lack of proximate cause; and immunity under section 4-106 of the Tort…”
Townsend v. City of Chicago, 2019 IL App (1st) 180771 (Ill. App. Ct. 2019). · cites it 3× “” 745 ILCS 10/4-106(b) (West 2014). ¶6 The parties then engaged in discovery.”
Ries v. City of Chicago, 950 N.E.2d 631 (Ill. 2011). · cites it 3× “The appellate court determined, inter alia, that the City was immune from liability pursuant to section 4-106(b) of the Local Governmental and Governmental Employees Tort Immunity Act (Tort Immunity Act) (745 ILCS 10/4-106(b) (West 2008)), which immunizes local public entities…”
Townsend v. City of Chicago, 2019 IL App (1st) 180771 (Ill. App. Ct. 2019). · cites it 3× “” 745 ILCS 10/4-106(b) (West 2014). ¶6 The parties then engaged in discovery.”
Bones v. City of Bloomington, 2022 IL App (4th) 210539-U (Ill. App. Ct. 2022). · cites it 3× “” ¶7 In April 2021, defendant filed a motion for summary judgment and a supporting memorandum of law asserting, “[p]laintiff’s claims are barred by the immunity provided in Section 4-106 of the Tort Immunity Act [(745 ILCS 10/4-106(b) (West 2020))].” ¶8 Following an August 2021…”
Show all 16 citing cases →
— 745 ILCS 10/4-106(b) — 15 cases
Robinson v. Vill. of Sauk Vill., 2022 IL 127236 (Ill. 2022). “OPINION ¶1 Section 4-106(b) of the Local Governmental and Governmental Employees Tort Immunity Act (Tort Immunity Act) (745 ILCS 10/4-106(b) (West 2016)) provides local public entities and public employees with absolute immunity from liability for “[a]ny injury inflicted by an…”
Doe-3 v. McLean Cnty. Unit Dist. No. 5 Bd. of Directors, 2012 IL 112479 (Ill. 2012). “, 745 ILCS 10/4-106(b) (West 2010) (“Neither a local public entity nor a public employee is liable for: Any injury inflicted by an escaped or escaping prisoner.”
Townsend v. City of Chicago, 2019 IL App (1st) 180771 (Ill. App. Ct. 2021). “” 745 ILCS 10/4-106(b) (West 2014). ¶6 The parties then engaged in discovery.”
Prough v. Madison Cnty., 2013 IL App (5th) 110146 (Ill. App. Ct. 2013). “The plaintiffs attempted to avoid application of section 4-106(b) of the Tort Immunity Act (745 ILCS 10/4-106(b) (West 2008)), immunizing a public entity for injury inflicted by an escaping prisoner, by arguing that section 4-106(b) did not cover the police officers’ conduct in…”
Wright-Young v. Chicago State Univ., 2019 IL App (1st) 181073 (Ill. App. Ct. 2019). “Compare 745 ILCS 10/4-105 (West 2012) (no liability for the negligent failure to provide medical care to a prisoner in custody), with 745 ILCS 10/4-106(b) (West 2012) (blanket immunity for “[a]ny injury inflicted by an escaped or escaping prisoner”).”
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