Blessing Hospital v. Illinois Health Facilities and Services Review Board

Plaintiff appealed from a trial court order dismissing its complaint for administrative review for failure to have summons issued within 35 days of service. Plaintiff argued on appeal that the service date was never established and, as a result, the 35-day period established in section 3-103 of the Administrative Review Law never commenced and that its summons were timely. The appellate court reversed and remanded, finding that the defendants did not establish the date on which service occurred and, consequently, they did not establish the date on which the period for plaintiff to appeal began to run. (HARRIS and ZENOFF, concurring)