Gaffney v. Board of Trustees of the Orland Fire Protection District, 2012 IL 110012

Gaffney and Lemmenes, Illinois firefighters, were injured in line-of-duty incidents while participating in training exercises and sought continuing health coverage benefits under 820 ILCS 320/10.
Gaffney’s injury occurred during a live-fire drill when a hose entangled with a loveseat, injuring his shoulder; he claimed the injury occurred while responding to what he reasonably believed was an emergency.
The board denied benefits, issuing a written Decision and Order, which Gaffney challenged in two counts: declaratory judgment and administrative review; the trial court treated the latter as a writ of certiorari.
The Fire Protection District Act did not expressly authorize administrative review of eligibility determinations under the Public Safety Employee Benefits Act; the district argued the board’s decision was a final administrative action subject to review.
The appellate court affirmed the trial court’s view that the board’s denial was an administrative decision; the Illinois Supreme Court reversed, holding the declaratory judgment path was proper and the statute’s scope did not authorize a traditional administrative review.
Lemmenes’ case involved a drill simulating a supermarket fire where he injured his knee; the trial court found he reasonably believed he was responding to an emergency, but the appellate court relied on DeRose to deem the situation an emergency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Gaffney’s declaratory judgment claim was proper	Gaffney: declaratory judgment appropriate to determine entitlement under the Act	Board: review only via administrative channels; declaratory judgment improperly bypasses that route	Declaratory judgment proper; remand on Gaffney’s claim
Whether the board’s denial of section 10 benefits is subject to administrative review	Gaffney contends the board’s decision is not an administrative action and not restricted to administrative review	District maintains the decision is an administrative action reviewable under Administrative Review Law	Board’s decision is not an administrative action subject to ARL; declaratory judgment appropriate
Whether section 10(b) emergency requires an unforeseen circumstance	Gaffney argues ‘emergency’ can include training evolutions and unforeseen events during training	District argues emergency must be a real, unforeseen crisis; training scenarios are not emergencies	Emergency includes unforeseen circumstances involving imminent danger; training turning into emergency can qualify

DeRose v. City of Highland Park, 386 Ill. App. 3d 658 (2008) (emergency defined as urgent, requiring immediate action)
Krohe v. City of Bloomington, 204 Ill. 2d 392 (2003) (catastrophic injury linked to line-of-duty status; interpretation of ‘catastrophic’)
Holly v. Montes, 231 Ill. 2d 153 (2008) (statutory interpretation must reflect plain meaning; avoid adding exceptions)
Manos v. Dept. of Professional Regulation, 202 Ill. 2d 563 (2002) (case cited for statutory interpretation principles)
People ex rel. Department of Professional Regulation v. Manos, 202 Ill. 2d 563 (2002) (statutory interpretation principles caution against extrinsic aids)
Davison v. People, 233 Ill. 2d 30 (2009) (undefined terms interpreted using dictionary to ascertain ordinary meaning)