Pinkston v. City of Chicago, 2023 IL 128575

In May 2019 Alec Pinkston received a $65 parking ticket labeled as a central business district (CBD) meter violation at/near 1216 S. Wabash; he contends that location is south of Roosevelt Road and therefore outside the CBD.
Pinkston paid the $65 fine (alleging payment was “under duress”) and filed a class-action complaint alleging the City routinely issued CBD tickets to vehicles parked outside the CBD, citing a news analysis of >30,000 such tickets (2013–2018).
He sought declaratory and injunctive relief and restitution/unjust enrichment for similarly situated motorists.
The City moved to dismiss under 735 ILCS 5/2-619(a)(9), arguing Pinkston failed to exhaust administrative remedies (DOAH process and Administrative Review Law) and that the voluntary payment doctrine barred relief.
The Cook County circuit court granted dismissal with prejudice for failure to exhaust; the appellate court reversed, finding the DOAH could not provide the classwide injunctive/monetary relief sought.
The Illinois Supreme Court reversed the appellate court and affirmed the circuit court: Pinkston failed to exhaust administrative remedies and no exception (including a class-action/systemic-practice exception) applied; the Court did not address the voluntary payment argument.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exhaustion of administrative remedies (and whether a class-action/systemic-practice claim may avoid exhaustion)	Pinkston: DOAH cannot provide the injunctive/monetary relief or redress systemic practice; exceptions to exhaustion apply.	City: Pinkston failed to raise the CBD-boundary defense at DOAH; administrative process (DOAH + administrative review) is the proper, adequate remedy; class action cannot bypass exhaustion.	Court: Pinkston failed to exhaust; no class-action or systemic-practice exception applies; dismissal affirmed.
Voluntary payment doctrine	Pinkston: Payment was compelled/under duress (threats of fees, collections, license suspension).	City: Voluntary payment bars recovery.	Court: Not reached — case disposed on exhaustion grounds.

Castaneda v. Illinois Human Rights Comm’n, 132 Ill. 2d 304 (Ill. 1989) (explains exhaustion doctrine and reasons for administrative review).
Canel v. Topinka, 212 Ill. 2d 311 (Ill. 2004) (lists exceptions to exhaustion requirement).
People ex rel. Naughton v. Swank, 58 Ill. 2d 95 (Ill. 1974) (class action cannot circumvent administrative-review requirements).
Midland Hotel Corp. v. Director of Employment Security, 282 Ill. App. 3d 312 (Ill. App. 1996) (administrative remedies are adequate; class action cannot avoid administrative review).
Board of Education of Chicago v. Board of Trustees of the Public Schools Teachers’ Pension & Retirement Fund of Chicago, 395 Ill. App. 3d 735 (Ill. App. 2009) (limited circumstances where systemic claims by nonparties may not be subject to administrative review).
Dvorkin v. Illinois Bell Telephone Co., 34 Ill. App. 3d 448 (Ill. App. 1975) (plaintiff cannot skip administrative remedies by invoking equity for a class action).