Illinois Compiled Statutes
820 ILCS 405/234 (2026)
Subject to the provisions of Sections 235 and 245 C, "wages" means every form of remuneration for personal services, including salaries, commissions, bonuses, and the reasonable money value of all remuneration in any medium other than cash
✓ current as of May 2026
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(820 ILCS 405/234)
(from Ch. 48, par. 344)
Sec. 234.
Subject to the provisions of Sections 235 and 245 C, "wages"
means every form of remuneration for personal services, including salaries,
commissions, bonuses, and the reasonable money value of all remuneration in
any medium other than cash. The reasonable money value of remuneration in
any medium other than cash shall be estimated and determined in accordance
with rules prescribed by the Director. Such rules shall be based upon the
reasonable past experience of the workers and the employing units concerned
therewith.
Where gratuities are customarily received by an individual in the course
of his work from persons other than his employer, such gratuities shall,
subject to the provisions of this paragraph, be treated as wages received
from his employer. Each such employer shall notify each such individual of
his duty to report currently the amount of such gratuities to such
employer and the Director shall, by regulation, prescribe the manner of
notification and of reporting. The amount of gratuities so reported shall
constitute a conclusive determination of the amount received unless the
employer, within the time prescribed by regulation, notifies the Director
of his disagreement therewith. Gratuities not so reported to the employer
in the manner prescribed by such regulations of the Director shall not be
wages for any of the purposes of this Act.
(Source: P.A. 84-1390.)
Notes of Decisions
Cited in 9
cases, 1995–2015 · leading case: SMRJ, INC. v. Russell, 884 N.E.2d 1152 (Ill. App. Ct. 2007).
SMRJ, INC. v. Russell, 884 N.E.2d 1152 (Ill. App. Ct. 2007). “” 820 ILCS 405/234 (West 1998). The evidence adduced at the administrative hearing established that when workers came to SMRJ, they completed and signed a document prepared by SMRJ and entitled “Application for Eligibility Verification.”
W. & S. Life Ins. v. Edmonson, 922 N.E.2d 1133 (Ill. App. Ct. 2009). “” 820 ILCS 405/234 (West 2006). “Remuneration” is defined broadly in Black’s Law Dictionary as “[pjayment; compensation.”
Hmelyar v. Phoenix Controls, 791 N.E.2d 695 (Ill. App. Ct. 2003). “See 820 ILCS 405/234, 235 (West 2000). Plaintiff argues in the alternative that, even if he did receive wages, the Board did not determine their value and thus did not decide whether either week’s wages were less than his weekly benefit amount.”
United Delivery Serv., Ltd. v. Didrickson, 659 N.E.2d 82 (Ill. App. Ct. 1995). “344 (now 820 ILCS 405/234 (West 1992)).) UDS argues that the money paid to drivers was solely for automobile rental payments under the equipment leases.”
Murphy v. Bd. of Review of Dep't of Emp. Sec., 917 N.E.2d 559 (Ill. App. Ct. 2009). “” 820 ILCS 405/234 (West 2006). Plaintiff argues that because his position as township supervisor did not include performing “personal services,” his compensation from that position cannot be considered “wages.”
Weinberg v. The Dep't of Emp. Sec., 2015 IL App (1st) 140490 (Ill. App. Ct. 2015). “The Board concluded Weinberg did not receive any “wages” as defined by section 234 of the Act (820 ILCS 405/234 (West 2010)) during the base period in 2009 and 2010 and was thus ineligible for unemployment benefits.”
Weinberg v. The Dep't of Emp. Sec., 2015 IL App (1st) 140490 (Ill. App. Ct. 2015). “" 820 ILCS 405/234 (West 2010). ¶ 23 The Act defines an "employing unit" to include a partnership.”
Hmelyar v. Phoenix Controls (Ill. App. Ct. 2003). “See 820 ILCS 405/234, 235 (West 2000). Plaintiff argues in the alternative that, even if he did receive wages, the Board did not determine their value and thus did not decide whether either week's wages were less than his weekly benefit amount.”
W. & S. Life Ins. Co. v. Edmonson (Ill. App. Ct. 2009). “" 820 ILCS 405/234 (2006). “Remuneration” is defined broadly in Black's Law Dictionary as "[p]ayment; compensation.”
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