Piasa Armory, LLC v. Raoul

In a direct appeal from an order of the trial court under SCR 302(a) and 304(a), the Illinois Supreme Court considered the constitutionality of section 2-101.5 of the Code of the Civil Procedure, which set venue in Sangamon and Cook Counties for actions seeking declaratory or injunctive relief from a constitutional challenge to a state statute, rule, or executive order. The trial court had ruled that the statute was unconstitutional as applied to individuals residing or injured outside of those two counties. The supreme court reversed and remanded, explaining that the statute was not unconstitutional as applied because requiring the plaintiffs to litigate claims in Sangamon or Cook County does not deprive them “of the opportunity to be heard in a meaningful time and in a meaningful manner.” (THEIS, NEVILLE, CUNNINGHAM, and O’BRIEN, concurring; HOLDER WHITE, specially concurring; and OVERSTREET, dissenting)