Howe v. The Retirement Board of the Firemen's Annuity and Benefit Fund of Chicago

Illinois Appellate Court
Civil Court
Case Number: 
2013 IL App (1st) 122446
Decision Date: 
September 9, 2013
1st Dist.
Cook Co.,1st Div.
Reversed; Board decision vacated; remanded with directions.
Retirement Board made procedural errors rendering its decision invalid. As Board never validly took final action on firefighter's disability application, Board's decision denying application, and court's ruling addressing merits of claim and affirming Board's decision are vacated. Board must conduct a proper affirmative vote on a specific written decision. Written decision of Board must be prepared and provided to each board member at or before time Board votes to take final action on application, and Board's only decision is the written version. (HOFFMAN and ROCHFORD, concurring.)