Shakari v. The Illinois Department of Financial and Professional Regulation

Plaintiff worked as a licensed health care worker, first as LPN and then as RN, for over 30 years.Illinois Department of Financial and Professional Regulation (IDFR was aware, when it initially approved LPN license, and in intervening years, when it consistently renewed his LPN and RN licenses, of Plaintiff’s prior conviction for attempted murder in 1975. IDFR permanently revoked Plaintiff’s RN license in 2015, pursuant to Section 2105-165 of Professional Regulation Law, which provided that when a licensed health care worker has been convicted of a forcible felony, license shall be permanently revoked.  Court properly concluded that Section applied to Plaintiff, and that it did not matter than Plaintiff’s conviction occurred before Plaintiff was licensed, or that felony offense was committed against a non-patient. Enactment of section 2105-165 eliminated IDFR’s discretion to renew licenses of such workers convicted of forcible felonies.  (PIERCE and HARRIS, concurring.)