Englum v. City of Charleston
2017 IL App (4th) 160747
| Ill. App. Ct. | 2017Background
- In December 2008, Charleston police officer Steven C. Englum slipped on ice while on duty and later was awarded a line‑of‑duty pension for the injury.
- In November 2013 Englum requested health‑insurance benefits under section 10 of the Public Safety Employee Benefits Act (Safety Benefits Act).
- In December 2013 the non‑home‑rule City of Charleston adopted an ordinance establishing an administrative hearing process (a mayor‑appointed hearing officer) to decide section 10 eligibility and scheduled a hearing for Englum.
- In February 2014 Englum filed two suits in Coles County: (1) declaratory relief asking the court to determine his section 10 eligibility, and (2) injunctive relief to bar the City’s administrative procedure.
- The City moved to dismiss, arguing Englum had to exhaust the local administrative process (ripeness/choice of remedy). The trial court denied dismissal, held a bench hearing on eligibility, and ruled Englum was entitled to section 10 benefits.
- On appeal the Fourth District reversed the denial of the City’s motion to dismiss (holding Englum should have used the City’s administrative process) and dismissed the separate appeal as to the injunctive action for lack of a final judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May a non‑home‑rule municipality create administrative procedures to determine eligibility under section 10 of the Safety Benefits Act? | Englum: City lacks authority to decide eligibility; declaratory relief in court is proper. | City: Municipal Code grants authority (65 ILCS 5/10‑4‑1, 1‑2‑1) to adopt procedures; Englum must exhaust them. | Held: City may enact such procedures under sections 10‑4‑1 and 1‑2‑1. |
| Is Englum’s declaratory action ripe before exhausting the City’s administrative process? | Englum: Court should decide eligibility now. | City: Claim is not ripe; must exhaust administrative remedies. | Held: Trial court erred; Englum must pursue the City’s administrative process (dismissal reversed). |
| Does the Safety Benefits Act preempt a local administrative scheme for section 10 claims? | Englum: State law controls; local scheme unlawful or inconsistent. | City: Act is silent on procedure and does not preempt local procedures; ordinance complements state law. | Held: No preemption—Act contains no procedural rules; local procedures are permissible and not inconsistent. |
| Was the trial court’s merits decision awarding section 10 benefits appropriate? | Englum: Merits decision in his favor. | City: Court should not have reached merits without exhaustion. | Held: Court did not reach the merits; appellate court declined to rule on entitlement because procedural route was improper. |
Key Cases Cited
- Gaffney v. Board of Trustees of the Orland Fire Protection District, 969 N.E.2d 359 (Ill. 2012) (held a fire protection district lacked statutory authority to create its own procedure for section 10 claims)
- Hawthorne v. Village of Olympia Fields, 790 N.E.2d 832 (Ill. 2003) (non‑home‑rule ordinances conflict with and must yield to a comprehensive state statutory scheme)
- Pesticide Public Policy Foundation v. Village of Wauconda, 510 N.E.2d 853 (Ill. 1987) (statewide, comprehensive regulatory scheme preempts local regulation)
- Beahringer v. Page, 789 N.E.2d 1216 (Ill. 2003) (exhaustion doctrine applies where claim is cognizable first in an administrative agency)