Plaintiff filed a class action lawsuit alleging that the defendant had engaged in the routine practice of improperly issuing central business district tickets or parking meter violations. The defendant moved to dismiss, arguing that the plaintiff had failed to exhaust his administrative remedies and had voluntarily paid his fine. The trial court granted the motion but the appellate court reversed. The Illinois Supreme Court reversed the appellate court and affirmed the trial court, finding that the plaintiff had failed to exhaust his administrative remedies and that no exceptions to the exhaustion doctrine were applicable. The supreme court did not consider defendant’s argument regarding the voluntary payment doctrine. (THEIS, NEVILLE, OVERSTREET, CUNNINGHAM, ROCHFORD, and O’BRIEN, concurring)
Illinois Supreme Court
Civil Court
Administrative Exhaustion