McCombie v. Welch

Illinois Appellate Court
Civil Court
Enrolled Bill Doctrine
Citation
Case Number: 
2026 IL App (4th) 250971
Decision Date: 
Tuesday, August 11, 2026
District: 
4th Dist.
Division/County: 
Sangamon Co.
Holding: 
Affirmed.
Justice: 
KNECHT

Plaintiffs, a group of 47 members of the Illinois General Assembly, filed a lawsuit seeking a declaration that Senate Bill 328, which amended jurisdiction related to toxic tort legislation, as unconstitutional because its passage allegedly violated the three-readings rule of the Illinois Constitution. The circuit court granted the defendant’s motion to dismiss on the basis that the enrolled bill doctrine bars judicial review of plaintiffs’ claim and that plaintiffs lacked standing and plaintiffs appealed. The appellate court affirmed, agreeing with the circuit court that the enrolled bill doctrine barred review of plaintiffs’ claim. The appellate court did not address the issue of standing, finding that it was superfluous. (DeARMOND and VANCIL, concurring)