Slepicka v. The State of Illinois

Illinois Appellate Court
Civil Court
Case Number: 
2013 IL App (4th) 121103
Decision Date: 
September 12, 2013
4th Dist
Sangamon Co.
Vacated and remanded with directions.
Plaintiff filed complaint for administrative review of IDPH decision approving involuntary transfer or discharge of nursing home,patient due to non-payment. Sangamon County was impermissible venue, as nursing home was located in, and Defendant issued notice of involuntary transfer in, and administrative hearing was held in, Cook County. Filing in wrong venue, per Code of Civil Procedure, counts for purposes of filing within time prescribed, and filing in wrong venue is not fatal to subject-matter jurisdiction. Payment of amount sought by nursing home does not render appeal moot. (STEIGMANN and HOLDER WHITE, concurring.)