Petitioner, an attorney, filed pro se complaint for administrative review contesting 2 parking tickets, issued 18 days apart. Petitioner appealed trial court's decision to deny his motion to consolidate and not consider his challenge to Department of Administrative Hearing's determination as to one ticket. A strict reading of Section 3-103 of Code of Civil Procedure requires filing of a complaint for each final administrative decision a party wishes to appeal, and no exception for mistakes made in good faith. As no complaint was filed for one ticket within 35-day review period, court was without jurisdiction to review DOAH's determination on that claim, even though Petitioner listed both ticket numbers on one timely-filed complaint. (SIMON and MIKVA, concurring.)
Illinois Appellate Court
Civil Court
Administrative Review