Dynak v. Board of Education of Wood Dale School District 7, 164 N.E.3d 1226

Margaret Dynak, a full‑time Wood Dale SD7 teacher, notified the district she would give birth on June 6, 2016, and sought to use accumulated sick leave for June 6–7 (1.5 days) and to apply 28.5 paid sick days at the start of the 2016–17 school year (beginning August 18) as part of her 12‑week FMLA leave. She had at least 30 accumulated sick days.
The District approved the 1.5 days in June and FMLA leave beginning August 18 but denied paid sick leave beginning in August, reasoning that the leave would not be temporally connected to the birth.
Dynak demanded reimbursement for 28.5 paid sick days, then filed suit for declaratory relief and attorney fees; the trial court granted summary judgment to the District.
The appellate court affirmed (majority: sick leave for birth must be contemporaneous with the event; dissent argued the statute allows post‑event use), and the Illinois Supreme Court granted leave to appeal.
The School Code provision at issue, 105 ILCS 5/24‑6, defines statutory sick leave to include "birth" and permits a physician’s certificate after an absence of 30 days for birth; the question was whether an intervening summer break prevents use of accumulated sick days after school resumes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether sect. 24‑6 allows a teacher who gives birth at school‑year end to use accumulated sick leave at the start of the next school year	Dynak: statute contains no temporal limit; "for birth" may be taken noncontinuous or later at teacher’s discretion	District: "sick leave" is tied to the qualifying event; an intervening nonwork period severs the temporal connection and 30‑day/physician rules support contemporaneous use	Held for District: sick leave for birth must be temporally connected; up to 30 days may be used in the six‑week period immediately following birth; beyond that a physician’s certificate is required; Dynak’s requested August leave was untimely
Whether Dynak is entitled to attorney’s fees under the Wage Act for unpaid wages allegedly due	Dynak: denial of paid sick days produced unpaid wages entitled to Wage Act fees	District: no wages were due because statute did not entitle Dynak to paid leave at that time	Held for District: no wages were due; Wage Act fees not available

Pielet v. Pielet, 2012 IL 112064 (summary judgment and cross‑motions principles)
Corbett v. County of Lake, 2017 IL 121536 (statutory construction: plain meaning and context)
Nowak v. City of Country Club Hills, 2011 IL 111838 (statute applied as written; resort to tools only if ambiguous)
People ex rel. Sherman v. Cryns, 203 Ill. 2d 264 (2003) (presumption that legislature did not intend absurd results)
Third Nat’l Bank in Nashville v. Impac Ltd., 432 U.S. 312 (1977) (noscitur a sociis doctrine cited for construing words in a list)