Tillman v. Pritzker, 183 N.E.3d 94

John Tillman filed a taxpayer petition under 735 ILCS 5/11-303 challenging the constitutionality of two series of Illinois general obligation bonds (2003 and 2017) as not being issued for constitutionally required “specific purposes.”
2003 statute authorized $10 billion in bonds for “state pension funding” (deposit to a Pension Contribution Fund); bonds issued June 2003. 2017 statute authorized $6 billion in “Income Tax Proceed Bonds” to pay vouchers incurred before July 1, 2017; bonds issued November 2017.
Tillman alleged the 2003 bonds were used for deficit financing and speculative lending to pension systems, and the 2017 bonds paid backlog vouchers from a budget impasse—none of which, he argued, fit Article IX, §9(b)’s “specific purposes” requirement.
The Sangamon County circuit court denied leave to file under §11-303, finding no reasonable ground; the Fourth District Appellate Court reversed and remanded, applying a narrow standard for “reasonable ground.”
The Illinois Supreme Court granted review, held the trial court may consider merits and affirmative defenses when evaluating §11-303 petitions, and ultimately affirmed the circuit court’s denial on the alternative ground of laches (extensive delay and prejudice to the State).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of “reasonable ground” under §11-303	“Reasonable ground” means only to screen frivolous or malicious suits; merits and defenses are off limits	Court may assess legal sufficiency and consider affirmative defenses when deciding reasonable ground	Rejected plaintiff’s narrow view; trial courts may examine legal merits and defenses in §11-303 review
Application of laches to taxpayer challenge of long‑issued bonds	Delay harmless because relief sought is prospective only	Delay (16 yrs for 2003 bonds; 2 yrs for 2017 bonds) and State action/bond payments cause prejudice; laches bars relief	Laches applies: petitioner’s unreasonable delay and prejudice to State mean no reasonable ground; petition denied
Abuse of discretion in denying leave to file	Appellate court: circuit abused discretion by considering merits	State: denial proper (no reasonable ground)	No abuse of discretion; circuit court decision affirmed (affirmed on laches grounds)

Strat-O-Seal Manufacturing Co. v. Scott, 27 Ill. 2d 563 (discussing leave‑to‑file inquiry and what may justify denial)
People ex rel. White v. Busenhart, 29 Ill. 2d 156 (purpose of §11-303 is to check indiscriminate taxpayers’ suits)
Lund v. Horner, 375 Ill. 303 (courts may review whether proposed complaint shows a right of action)
Wirtz v. Quinn, 2011 IL 111903 (affirming denial of leave where constitutional claims failed as a matter of law)
Solomon v. North Shore Sanitary District, 48 Ill. 2d 309 (laches bars late taxpayer suits after bonds issued and funds expended)
Pyle v. Ferrell, 12 Ill. 2d 547 (definition and elements of laches)
Di Santo v. City of Warrenville, 59 Ill. App. 3d 931 (laches where bonds transferred and public relied on transaction)
Bowman v. County of Lake, 29 Ill. 2d 268 (matters of public record give constructive notice; delay can bar taxpayer action)