Illinois Appellate Court
Civil Court
Sovereign Immunity
Plaintiff filed suit seeking declaratory judgment as to amendment to Illinois Estate and Generation-Skipping Transfer Tax Act. Court erred in dismissing Plaintiff's suit as barred on grounds of sovereign immunity. The voluntary-payment doctrine does not provide alternative ground for affirming dismissal, as the prospect of penalties, interest, and personal liability amounted to duress, so that Plaintiff's payment of estate tax was not voluntary. Plaintiff's allegations fall within the officer-suit exception, and thus sovereign immunity is not implicated. (ZENOFF and SCHOSTOK, concurring.)