Author: Chris Peters

Jeffrey Krumpe Represented the Bank In a Farm Chapter 11 Case

Jeffrey Krumpe represented the Bank in a farm Chapter 11 case, where Debtors obtained crop input financing by agreeing to sell future farm receipts to finance company, contrary to interest of Bank with prior perfected security interest in crops and proceeds, and where the Bank and the finance company claimed a competing interest in certain crop proceeds, Court determined on the facts at trial that Bank had not “authorized the disposition free of” its security interest under U.C.C. 9-315(a)(1), so that the Bank retained its lien on Debtors’ crops and proceeds notwithstanding alleged sale to finance company. Court also determined that the evidence did not support finance company’s alternative theory of Equitable Subordination under Bankruptcy Code section 510(c), finding that Bank did not exert excessive control over Debtors’ business, and thus was not an insider, and took no inequitable action with an intent to harm the finance company.

The court’s opinion can be found here:

Click to access 19-8072_Brooks%20vs%201st%20Midwest%20Bank.Opinion.pdf


Court affirms Pension Board’s denial of City’s request to intervene in firefighter line of duty disability hearing.

By: Robert B. McCoy

Illinois municipalities with a population of 5,000 or more are required to create a pension fund for firefighters or police officers in their employ. Those municipalities have a substantial financial interest in the disposition of disability pension claims, especially line of duty pension claims, made by the pension fund’s administering board. Not only do line of duty pensions pay greater benefits than “normal” disability pension (65% of a firefighter’s monthly salary for a line of duty disability versus 50% of the firefighter’s monthly salary for a non-line of disability, and up to 75% of a police officer’s monthly salary for a line of duty disability versus 50% of the police officer’s monthly salary for a non-line of disability), the award of a line of duty pension may preclude a municipality from being able to contest whether a firefighter or police officer claimant is entitled to a lifetime of health insurance benefits under the Public Safety Employee Benefits Act (PSEBA).

Local fire and police pension boards are charged with the fiduciary responsibility of administering their pension funds to ensure there are adequate financial resources to cover obligations to pay current and future retirement and disability benefits to qualified beneficiaries. To this end, pension boards are charged to hold hearings to screen out unqualified or fraudulent disability claims. But pension boards may not always adequately protect the financial interests of the cities or villages which underwrite the pension fund.

Despite their financial interest in the outcome of disability pension claims, there is no statutory right for municipalities to participate in pension board hearings. Instead, Illinois courts have ruled that pension boards have discretion to allow or disallow a municipality to intervene in a disability claim hearing.

A pension board’s discretion is not absolute. But, as recently reaffirmed by the Illinois Appellate Court in the case City of Peoria v. Firefighters’ Pension Fund of City of Peoria, 2019 IL App (3d) 190069, decided December 10, 2019, it is not error for a pension board to deny a municipality’s request to intervene in a disability claim hearing unless the municipality can show that is has something more at stake than the normal financial concerns inherent in all such cases. In the words of the Court, “[A] municipality’s interest in the proper expenditure of pension funds may warrant intervention in pension board proceedings when combined with another interest.”

In the City of Peoria case (in which this author represented the claimant firefighter), the City of Peoria argued that the Firefighters’ Pension Fund had wrongly denied it the right to intervene in the hearings to determine whether a firefighter was entitled to a line of duty disability pension. The City asserted, on administrative review of the decision before the Circuit and Appellate Courts, that the City’s potential liability for PSEBA was “another interest” which warranted it being allowed to intervene in the pension hearings.

Under the unique facts of the case, the Appellate Court disagreed. The Appellate Court noted that a pension board’s finding that a firefighter became disabled in the line of duty was conclusive as to the issue of whether a firefighter suffered a “catastrophic injury” for purposes of PSEBA eligibility. But, a duty-related disability is not all that is required for a firefighter or police officer to be eligible for PSEBA. PSEBA also requires that the injury “must have occurred as the result of the officer’s response to fresh pursuit, the officer or firefighter’s response to what is reasonably believed to be an emergency, an unlawful act perpetrated by another, or during the investigation of a criminal act.” In the City of Peoria case, the firefighter conceded that his injury did not occur as a result of an emergency (or any other PSEBA-qualifying event). Thus, because the firefighter was ineligible for PSEBA, the City could not rely on the threat of PSEBA liability as grounds to intervene in the pension case.

The City of Peoria also asserted that the City had an interest in developing a complete and accurate record in the pension board hearings. The Appellate Court acknowledged that this could be a sufficient reason for intervention by a municipality. But, under the facts presented, the pension board did not err in denying the City’s request to intervene, where the City was allowed to submit documentary evidence to the pension board, and the City failed to identify what additional evidence it would have presented had it been allowed to fully intervene, or how such evidence would have changed the outcome of the hearings.

Because it was not formally allowed to intervene in the pension hearings, the City of Peoria never became a “party” to those administrative proceedings. The Appellate Court noted that, because the City was not a party to the pension board hearings, there was an argument that the City lacked “standing” to even bring a lawsuit to challenge the pension board’s decision. The Court acknowledged that judicial review of an administrative decision (such as review of a pension board decision) is generally “limited and available only to (1) parties of record to the proceedings before the administrative agency (2) whose rights, duties, or privileges were adversely affected by the agency’s decision.” The Appellate Court declined to decide whether the City of Peoria lacked standing, where the firefighter did not file a cross-appeal on this issue, but the Court left open the possibility that, in future cases, municipalities who do not obtain party status will not have a right to seek review of adverse pension board decisions.

The chief lesson of the City of Peoria case is that municipalities cannot assume their voice will be heard when firefighters and police officers make disability claims. Municipal officers should work closely with their attorneys to identify each and every special circumstance that warrants their participation in a particular claimant’s pension board hearing. One special circumstance which may be relevant is avoidance of PSEBA liability, where doubts exist that a police officer or firefighter is really disabled, or whether the disability is really related to the employee’s duties, but PSEBA will not be an issue in all disability claims. If a municipality is denied the right to participate in a disability hearing, it needs to be prepared to describe what evidence or testimony it would have introduced at the hearing, had it been allowed to intervene. Failing to do so might result not only in an adverse pension board decision, it might result also in the municipality forfeiting its right to appeal the decision.

Illinois Supreme Court Clarifies use of Paid Sick Leave Following Birth of a Child

Teacher denied right to continue paid maternity leave following intervening summer break.

By:  Katherine L. Swise

In the case of Dynak v. Board of Education of Wood Dale School District No.7 (2020 IL 125062), the Illinois Supreme Court was asked whether accrued paid sick leave may be used to extend a teacher’s maternity leave into a new school year.  In a decision issued on April 16, 2020, the Court answered this in the negative, holding that a teacher who gave birth to a child prior to the end of the school year was not entitled to use her remaining accrued sick leave when school resumed in the fall.

The Dyank case involved a full-time teacher who gave birth to a child on the second-to-last day of the school year.  She requested and was granted use of accrued paid sick leave for those remaining 1.5 days of school.  When school resumed following the summer break, she made a request for 12 weeks of leave pursuant to the Family Medical Leave Act, and also requested to substitute 28.5 days of accrued paid leave for the first part of her FMLA leave.  The school district granted her request for FMLA leave but denied her request to substitute accrued paid sick leave, unless the teacher was able to demonstrate circumstances that allowed the use of paid sick leave pursuant to Section 24-6 of the Illinois School Code. 

Section 24-6 of the School Code provides for paid sick leave for full-time teachers, and interprets “sick leave” to include “personal illness, quarantine at home, serious illness or death in the immediate family or household, or birth, adoption, or placement for adoption.”  105 ILCS 24-6.  Section 24-6 further provides that a school district may require a doctor’s certification for absence of in excess of 3 days for personal illness or 30 days for birth.  The school district argued that, because the teacher’s request for paid sick leave in this case was more than 30 days (6 weeks) after the birth, she was not entitled to use paid sick leave without a doctor’s certification, or unless another triggering event applied.  The teacher argued that the School Code does not specify that paid sick leave for birth must be continuous or that it must be commenced or used within a certain period following the birth, and thus she was entitled to use her accrued sick leave after the summer break.

The Supreme Court rejected the teacher’s argument that she was entitled to use paid accrued sick leave at any time following the actual birth.  Rather, the Court held that the language of Section 24-6 “strongly suggests that the legislature intended that sick leave for birth must have a temporal connection to the birth.”  If a teacher could use their paid sick leave at any time after the birth, the Court reasoned, it would make no sense to require a doctor’s note for a period in excess of 30 days.  The Court further noted that there is no indication that the legislature intended sick leave for the birth of a child to operate any differently from sick leave for any other triggering event, such as personal illness or a death in the immediate family.  It would be absurd to require school districts to allow a teacher who got sick or had a death in the family over summer break to use accrued paid sick leave for those events once school resumed.  It is clear in those cases that the paid leave must be used at the time those events occur, and not at some later time of the teacher’s choosing.  Similarly, the Court held that paid sick leave for birth must be used at the time of the birth.  Thus, the Court held that the teacher in this case was not entitled to use accrued paid sick leave when school resumed after the summer break because the “triggering event”—in this case, the birth—had occurred more than 10 weeks earlier.

It is important to note that the Court’s holding in this case was limited to the facts of this case.  The Court implied that the outcome would have been different if the teacher was able to provide medical documentation supporting her need for additional sick leave so long after the actual birth.  Thus, there may be circumstances under which an employee would be permitted to use accrued paid sick leave for the birth of a child, even after an intervening summer break.  Additionally, she was granted unpaid leave under FMLA, which can be taken any time within the first year after the birth of a child. 

It is also important to note that there may be an applicable collective bargaining agreement provision that could change the outcome in a particular case.  There was no discussion of whether the teacher in this case was entitled to use her paid leave pursuant to the provisions of a collective bargaining agreement, so it is presumed that there was no applicable contract provision in this case.  However, school districts should take care to review the terms of their own collective bargaining agreement before relying on the outcome of this case to deny a teacher’s request for paid leave after an intervening summer break.  As always, be sure to consult your board attorney if you have any questions about the application of the Court’s holding in this case to your paid sick leave policy.

Changes to Ashley’s Law: What Does It Mean for Medical Marijuana in Schools?

Governor signs bill expanding the administration of medical marijuana to students.

By:  Kateah M. McMasters

On August 12, 2019, Governor Pritzker signed Senate Bill 455 expanding “Ashley’s Law”, which currently allows a parent, guardian or designated caregiver to administer medical marijuana to a student with a valid prescription on school grounds and on school buses.

The law’s expansion (Public Act 101-0370) amends Section 22-33 of the Illinois School Code to require school districts, public schools, charter schools, and non-public schools to allow a school administrator or nurse to administer a “medical cannabis infused product” (i.e. edible and topical products) to a student that is a registered qualifying patient under the Compassionate Use of Medical Cannabis Program Act while on school grounds, at school-sponsored activities, at before or after school care on school grounds, or on a school bus.  However, the law does not explicitly require school administrators or nurses to actually administer medical marijuana to students; instead, the amendment only requires schools to allow these personnel to administer medical marijuana to a student if they are willing to do so.

The amendment also permits schools to authorize students to self-administer their own medical marijuana under the direct supervision of an administrator or nurse.  As with the change discussed above, the law does not explicitly require schools to allow its students to self-administer their medical marijuana; however, they are permitted to do so.

Additional requirements and training

In order for a school administrator or nurse to administer medical marijuana to a student, or for a student to self-administer medical marijuana, the parent or guardian must provide the following to the school:

(1) written authorization for its use, including the time where or the special circumstances under which the medical marijuana must be administered, and

(2) a copy of the registry identification card of the student (as a registered qualifying patient) and the parent or guardian (as a designated caregiver).

If a school permits self-administration by a student, the authorization must be renewed each school year.

Medical marijuana to be administered by a school nurse or administrator, or self-administered by the student, may now be stored on school property, but it must be stored in the same manner as all other student medication at the school, and can only be accessed by the school nurse or an administrator.

Personnel who elect to administer medical marijuana to students must complete training on the administration of medical cannabis infused products before they may administer cannabis to students.  The training will be developed by the Illinois State Board of Education and Illinois Department of Public Health., and must be completed annually.

Finally, the new law amends Section 25 of the Compassionate Use of Medical Cannabis Program Act to extend its immunities to school administrators and nurses who elect to administer medical cannabis to students or to assist students in self-administration under the School Code.  Such nurses and administrators are immune from arrest, prosecution, and denial of any right or privilege, including a civil penalty.  However, unlike the immunities for designated caregivers, school nurses and administrators are not immune from disciplinary action by an occupational or professional licensing board.

Next steps

The new law takes effect on January 1, 2020. Prior to the effective date schools should review their policies addressing the administration of medical marijuana as necessary. Schools without such policies should come into legal compliance by establishing them, because such policies were required when Ashley’s Law first became effective on August 1, 2018.  

Schools are encouraged to contact legal counsel to discuss the impact of the changes to Ashley’s Law and to formulate a new policy regarding the use of medical marijuana by qualifying students on school buses and school grounds that is consistent with the amendments to the School Code.

Residency Requirements for Municipal Employees

By:  Robert B. McCoy

In most cases, a municipality can chose whether to mandate that its employees reside within the municipality’s corporate limits.   Special rules, however, apply to police officers, firefighters and appointed officers of a municipality.

Municipalities that have chosen to impose employee residency requirements have sometimes faced constitutional challenges to their policies.  These challenges seldom succeed in the courts.  All that is needed for an employee residency requirement to be constitutional is that the municipality had a “rational basis” for adopting the requirement.  This standard can be easily met.  The Seventh Circuit Court of Appeals (the federal appeals court that sits in Chicago) has noted, for example, that a city’s need to have its employees sometimes available on short notice is a sufficient, rational reason for a residency requirement to make it constitutional.  Gusewelle v. City of Wood River, 374 F.3d 569, 578 (7th Cir. 2004.)

Although municipalities may choose to impose residency requirements on employees, the Municipal Code provides that certain appointed municipal officers must be residents. The default rule is that all appointed officers must be residents of the municipality in which they serve. (65 ILCS 5/3.1-10-6.) However, the Municipal Code exempts from this residency requirement “municipal engineers, health officers, attorneys, or other officers who require technical training or knowledge.”  There are no reported court cases giving guidance on this point, but it appears that a city council or village board could not adopt an ordinance imposing a residency requirement on “municipal engineers, health officers, attorneys, or other officers who require technical training or knowledge,” where such an ordinance would probably constitute an unlawful restriction on the mayor’s or village president’s authority to appoint officers of his or her choosing to these offices.

Police officers and firemen are considered officers, and per default rule, they must be residents of their municipality.  But, unlike the case for other officers, the Municipal Code expressly provides that a municipality can adopt an ordinance that changes this default rule and not require that its police officers and firemen be residents.  It is our opinion that a municipality could also exclude its police chief or fire chief from any residency requirements.  Note that for municipalities whose police officers of firemen are appointed by a board of police and fire commissioners, residency requirements for police officers or firemen cannot be made more restrictive for any individual during his or her period of service, nor can residency be made a condition of promotion, except for the rank or position of fire or police chief.  (65 ILCS 5/10-2.1-6.)

Who is an officer of a municipality, as opposed to a mere employee, is not always clear.  The Municipal Code lists the following positons, which may be filled by the mayor or village president with the advice and consent of the city council or village board, as being appointive offices:  “(1) a treasurer (if the treasurer is not an elected position in the municipality), (2) a collector, (3) a comptroller, (4) a marshal, (5) an attorney or a corporation counsel, (6) one or more purchasing agents and deputies, (7) the number of auxiliary police officers determined necessary by the corporate authorities, (8) police matrons, (9) a commissioner of public works, (10) a budget director or a budget officer, and (11) other officers necessary to carry into effect the powers conferred upon municipalities.”  (65 ILCS 5/3.1-30-5.)  This last category is vague, but the courts have provided some guidance in its interpretation.  In determining whether a person is an employee or an officer, the courts look at whether appointment is for a certain term, whether an oath of office is required, and whether the person has the supervisory and discretion to act on behalf of the municipality.   Rinchich v. Village of Bridgeview, 235 Ill. App. 3d 614, 628, 601 N.E.2d 1202, 1211 (1st Dist. 1992).

If a position is held by an appointed officer, as opposed to a hired employee, and if there is no statutory exception that allows or requires the officer to be a non-resident, the Municipal Code requires that the person to be a resident.  For example, an appointed city administrator, who exercises a large amount of discretion in the performance of his or her duties, would likely be an officer, and without an applicable exception to the default rule that appointed officers must be residents, the city administrator would be required to be a city resident.

In summary:

  1. A municipality can choose whether to require residency of its “ordinary” employees.
  2. A municipality can choose whether to require residency of its police officers and firemen.  However, if there is no ordinance providing otherwise, police officers and firemen must be residents of the municipality.
  3. A city council or village board likely lacks the authority to require residency of the municipality’s attorney, engineer, or any officer required to have technical training or knowledge. Imposing a residency requirement improperly limits the mayor’s or village president’s power to make appointments to these offices.
  4. Other appointed officers of a municipality may be required by statutes to be residents of the municipality. Consult with your attorney if you have questions whether an appointed officer can reside outside of your municipality’s corporate limits.

Miller, Hall & Triggs Attorney presents seminar on Real Estate Closings

On March 21, 2018, Christopher Oswald of Miller, Hall & Triggs presented on the topic of Real Estate Closings as a part of the Peoria County Bar Association’s “Brown Bag” continuing legal education series of seminars.  Together with another local attorney, Mr. Oswald emphasized planning and communication at the earliest stages of the transaction as key elements of bringing a transaction to a successful close- emphasizing that in order to best represent a client’s interest, practitioners should pay attention to often overlooked issues and make a point to have effective communication with all parties and professionals assisting with the transaction.


Mr. Oswald regularly assists clients of Miller, Hall & Triggs, LLC in a wide range of real estate issues, and has developed relationships with professionals throughout the State of Illinois to assist clients in planning for, structuring and bringing to a successful close a variety of real estate transactions.  He presently serves as Chairman of the Peoria County Bar Association Real Estate Committee.



Press Release

The law firm of MILLER, HALL & TRIGGS, LLC is pleased to make the following announcements regarding the attorneys at our firm.  As of January 1, 2018, Katherine L. Swise has become a member of the firm.  Also, Jennifer Klein VandeWiele and Nancy L. Rabel have become Of Counsel with the firm.  Further, the firm recently welcomed Kathleen M. Carter and Lauren A. Christmas as our newest Associates with the firm.  With our continued focus in the practices areas of local government and municipal law, education law, commercial and residential real estate, business and corporate law, and estates and trusts, we are excited to have these attorneys join our team at Miller, Hall, & Triggs, LLC.

Changes to the Juvenile Court Act

Records of Municipal Ordinance Violations to be Kept Confidential & Automatic Expungement of Law Enforcement Records


Effective January 1, 2018, two important changes were made to the Juvenile Court Act of 1987 (705 ILCS 405/1-1 et seq.) (the “Act”) concerning records of minors who are investigated, arrested or taken into custody prior to the minor’s 18th birthday.


Under prior law, the Act only applied to the courts and law enforcement agencies (which include municipal police departments), rather than to units of local government themselves.


However, within the recent changes to the Act, municipalities are now required to keep confidential all records of municipal ordinance violations that are maintained by the municipality and which relate to a minor who has been investigated, arrested or taken into custody prior to the minor’s 18th birthday.  Except in certain limited situations, such ordinance violation records are not subject to disclosure, inspection, or copying.


This change to the Act will likely not have a significant impact upon those municipalities which utilize a law enforcement agency for the issuance of ordinance citations because records that are maintained by law enforcement agencies were previously subject to the Act’s confidentiality and disclosure rules.  However, those municipalities which do not utilize a law enforcement agency for the issuance of ordinance citations (i.e. code enforcement officers or marshals) are now subject to these rules.


Specifically, municipalities are now prohibited from disclosing to the general public any records pertaining to an ordinance violation by a minor.  In addition, municipalities are only authorized to allow the inspection and copying of a minor’s ordinance violation record(s) in very limited circumstances, including, but not limited to, the following:


  1. Any local, State, or federal law enforcement officer when necessary for the discharge of their official duties;
  2. Prosecutors, probation officers, social workers, and other individuals assigned by the court and in connection with criminal proceedings;
  3. Department of Children and Family Services (DCFS); and
  4. Appropriate school officials only if there is an imminent threat of physical harm to students, school personnel, or others present in the school or on school grounds.


Interestingly, the Act does not create an exception for the disclosure, inspection or copying of records by the subject minor, the minor’s parents or guardians, or an authorized agent.  While the Act may not explicitly authorize such action, it may nevertheless be required under the law.  Municipalities should consult with counsel prior to any disclosure, inspection or copying of records which relate to a minor.


The second change, while only impacting law enforcement agencies, imposes a rather large burden upon local law enforcement agencies and municipal police departments.  The Act now requires all law enforcement agencies to expunge or permanently destroy certain records that are maintained by the law enforcement agency pertaining to minors on an annual basis.  These records, which are called “law enforcement records”, include, but are not limited to, records of arrest, station adjustment, fingerprints, probation adjustments, the issuance of a notice to appear, and any other records or documents relating to a minor suspected of committing an offense or evidence of interaction with law enforcement (i.e. ordinance violations).


This new requirement mandates that, on or before January 1st of each year, all law enforcement agencies within the State of Illinois automatically expunge all law enforcement records, except records for a serious felony offense, relating to events occurring before an individual’s 18th birthday.  However, such law enforcement records must meet the following requirements in order to qualify for automatic expungement:


  1. One year or more must have passed since the date of arrest or the documented law enforcement interaction;
  2. No petition for delinquency or criminal charges has been filed relating to the arrest of documented law enforcement interaction; and
  3. Six (6) months must have passed without an additional or subsequent arrest or filing of a petition for delinquency or criminal charges.


Local law enforcement agencies and municipal police departments should work with counsel and the State’s Attorney’s Office to ensure that records qualify for expungement prior to their destruction.


Municipalities are also reminded that expunged juvenile records may not be considered in employment matters.  The Act requires applications for employment, including employment with a public body, to contain a statement that the applicant is not obligated to disclose expunged records relating to any act(s) that was committed while the applicant was a minor.

Miller Hall & Triggs closes on two RAD Low Income Housing Tax Credit Transactions in December 2017

Richard M. Joseph with Miller, Hall & Triggs, LLC closed on two RAD Low Income Housing Tax Credit Transactions in December 2017 benefiting the Housing Authority of the City of Rock Island, Illinois and its affiliated not for profit corporation and the Housing Authority of the City of Pine Bluff, Arkansas and its affiliated not for profit corporation.

The RAD program,  administered by HUD,  was established in order to give public housing authorities a powerful tool to preserve and improve public housing projects and address issues of deferred maintenance by providing for the voluntary conversion of public housing and other HUD-assisted properties to long-term, project-based Section 8 rental assistance, utilizing either project-based vouchers or project-based rental assistance contracts. RAD allows public housing agencies to leverage public and private debt and equity to help ensure that the units remain affordable to low income households.

The Rock Island, Illinois project made possible the conversion and rehabilitation of 141 units in an eleven story apartment building through the use of 4% low income housing tax credits generating $3,590,410 in equity, $6,100,000 Multi-family Housing Revenue Bonds issued through the Illinois Housing Development Authority, $4,487,200 non-recourse loan through the HUD 223(f) program, and use of Public Housing Operating Reserve Funds and Replacement Housing Factor Funds.

The Pine Bluff, Arkansas project made possible the conversion and substantial rehabilitation of 251 units in four separate apartment complexes through the use of 4% low income housing tax credits generating $5,557,636 in equity, $10,500,000 Multi-family Housing Revenue Bonds issued through the Arkansas Development Finance Authority, $7,055,400 non –recourse loan through the HUD 223(f) program and use of Public Housing Operating Reserve Funds and Public Housing Capital Funds.

Governor Mandates Public Entities Enact Policies Prohibiting Sexual Harassment by January 15, 2018

  On November 16, 2017, Governor Rauner signed into law Public Act 100-0554, which amends the Illinois State Officials and Employees Ethics Act by requiring local governmental entities to adopt, by ordinance or resolution, a policy prohibiting sexual harassment.  5 ILCS 430/70-5.  Although many governmental entities may already have sexual harassment policies in place, the law sets forth new minimum standards for all policies.  According to the new amendments, a policy prohibiting sexual harassment shall include, at a minimum:

  • a prohibition on sexual harassment;
  • details on how an individual can report an allegation of sexual harassment, including options for making a confidential report to a supervisor, ethics officer, Inspector General, or the Department of Human Rights;
  • a prohibition on retaliation for reporting sexual harassment allegations, including availability of whistleblower protections under this Act; and
  • the consequences of a violation of the prohibition on sexual harassment and the consequences for knowingly making a false report.

     For purposes of the Illinois State Officials and Employees Ethics Act, “governmental entity” is defined as “a unit of local government (including a community college district) or a school district but not a State agency or a Regional Transit Board.” 5 ILCS 430/1-5.  This would include, but not be limited to municipalities, counties, townships, park districts, school districts, and community college districts.  All governmental entities should review their current sexual harassment policies to ensure that they meet the minimum standards and were properly approved by either resolution or ordinance by the January 15, 2018 deadline. To view the full Act, see Public Act 100-0554