Illinois Appellate Court
Civil Court
Municipal Law
Defendant appealed from trial court judgment finding it guilty of violating the Downers Grove Fire Prevention Code. The appellate court affirmed, finding that the village’s annual testing requirement did not violate defendant's residents' fourth amendment right to be free of unreasonable searches and that defendant's due process rights were not violated when the village initiated court proceedings without first allowing defendant to pursue administrative appeal procedures. The appellate court modified the amount of the fine imposed for failure to comply with the code. (McLAREN and SCHOSTOK, concurring)