ILCS » Chapter 820 · Act 115
Illinois Compiled Statutes

820 ILCS 115/13 (2026)

In addition to an individual who is deemed to be an employer pursuant to Section 2 of this Act, any officers of a corporation or agents of an employer who knowingly permit such employer to violate the provisions of this Act shall be deemed to be the employers of the employees of the corporation

✓ current as of May 2026
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(820 ILCS 115/13) (from Ch. 48, par. 39m-13)
    Sec. 13. In addition to an individual who is deemed to be an employer pursuant to Section 2 of this Act, any officers of a corporation or agents of an employer who knowingly permit such employer to violate the provisions of this Act shall be deemed to be the employers of the employees of the corporation.
(Source: P.A. 96-1407, eff. 1-1-11.)

    
Notes of Decisions
Cited in 28 cases (6 in the last 5 years), 2000–2026 · leading case: Andrews v. Kowa Printing Corp., 838 N.E.2d 894 (Ill. 2005).
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Andrews v. Kowa Printing Corp., 838 N.E.2d 894 (Ill. 2005). · cites it 10× “" 820 ILCS 115/13 (West 2002). We begin our analysis with section 2, which states that "any person * * * acting directly or indirectly in the interest of an employer in relation to an employee" is deemed an "employer" for purposes of the Wage Act.”
Watts v. ADDO Mgmt., L.L.C., 2018 IL App (1st) 170201 (Ill. App. Ct. 2018). · cites it 3× “where wage payments are made directly or indirectly by the agency or business for work undertaken by employees under hire to a third party pursuant to a contract between the business or agency with the third party, or any person or group of persons acting directly or indirectly…”
Elsener v. Brown, 2013 IL App (2d) 120209 (Ill. App. Ct. 2013). · cites it 3× “” 820 ILCS 115/13 (West 2012). ¶ 57 As we read the interplay of these provisions, any “employer,” whether person or entity, must be “in this State” for the Wage Act to apply.”
Catania v. LOCAL 4250/5050, 834 N.E.2d 966 (Ill. App. Ct. 2005). · cites it 2× “In addition, “[a]ny officers of a corporation or agents of an employer who knowingly permit such employer to violate the provisions of this Act shall be deemed to be the employers of the employees of the corporation.”
Andrews v. Kowa Printing Corp., 814 N.E.2d 198 (Ill. App. Ct. 2004). · cites it 2× “820 ILCS 115/13, 14(a) (West 2000). The parties have not cited, nor has our own research disclosed, any case holding an “innocent” corporate officer individually liable under section 5 of the Wage Act.”
DeGeer v. Gillis, 707 F. Supp. 2d 784 (N.D. Ill. 2010). · cites it 2× “In particular, DeGeer cites 820 ILCS 115/13, which provides that “[a]ny officers of a corporation or agents of an employer who knowingly permit such employer to violate the provisions of this Act shall be deemed to be the employers of the employees of the corporation.” 820 ILCS…”
Zabinsky v. Gelber Grp., Inc., 807 N.E.2d 666 (Ill. App. Ct. 2004). “” 820 ILCS 115/13 (West 2000). Trial testimony from plaintiff, Brian Gelber and Franklin Gelber established that plaintiff was hired by Brian and Franklin Gelber to work for GMI, a subsidiary of GGI.”
Byung Moo Soh v. Target Mktg. Sys., 817 N.E.2d 1105 (Ill. App. Ct. 2004). “The ruling of the Doherty court follows: “Plaintiff asserts that, as an employee of Glen Regal, he was within the class of persons the Wage Act was designed to protect.”
Watts v. ADDO Mgmt., L.L.C., 2018 IL App (1st) 170201 (Ill. App. Ct. 2018). · cites it 3× “” 820 ILCS 115/13 (West 2014). ¶ 15 Our courts have previously held that because of the deliberate breadth of the Wage Act’s definition of “employer,” the “necessity to plead that a defendant is an employer does not add any requirement beyond what is necessary to plead the…”
Covinsky v. Hannah Marine Corp., 903 N.E.2d 422 (Ill. App. Ct. 2009). “” 820 ILCS 115/13 (West 2006). If Hannah meets this definition, he is an “employer” under the Wage Act and can be held individually liable to Covinsky Catania v.”
Armstrong v. Hedlund Corp., 738 N.E.2d 163 (Ill. App. Ct. 2000). “The order specifically stated: “Plaintiffs cause of action arose and accrued on October 18, 1993 (the date of her alleged termination) and not a later date that the Defendants could have relied upon under 820 ILCS 115/5 [(Wage Act)], the cause of action accrues for statute of…”
Midway Games, Inc. v. Anonuevo (In Re Midway Games, Inc.), 428 B.R. 327 (Bankr. D. Del. 2010). “’’ 820 ILCS 115/13 (2010). 4 . Among the fifteen former employees named in this adversary proceeding, IDOL only represents eleven of the fifteen employees at this time.”
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