The following is a synopsis of selected decisions of the Illinois Appellate Courts, the Illinois Supreme Court and Federal Courts that have been rendered since the 1984 Illinois Municipal League Annual Conference. Included also are selected law review articles and opinions of the Illinois Attorney General.

There have been a number of notable decisions in the past year and we have attempted to highlight those which appear most significant to municipal attorneys and public officials.

Decisions have been rendered regarding home rule powers, antitrust, municipal ordinances, zoning, freedom of speech restrictions and civil rights discriminations.

Articles have been published concerning municipal antitrust liability, employee civil rights, home rule and other topics which are well worth reading.

State Mechanical Contractors v. Village of Pleasant Hill
87 Ill. Dec. 532
477 N.E.2d 509
Unsuccessful bidder on public works project who submits best responsive bid has a cause of action to recover from public body expenses incurred in preparing and presenting that bid but may not recover alleged lost profits.

Gust v. Village of Skokie
80 Ill. Dec. 584
465 N.E.2d 696
Home rule ordinance declaring employee wage and benefit disputes not be submitted to arbitration superseded prior conflicting State statute requiring arbitration board hearing for labor disputes involving fire department. Ordinance applied, even though it was enacted after action was filed.

Peoples Gas, Light & Coke Company v. City of Chicago
80 Ill. Dec. 491
465 N.E.2d 603
City ordinance imposing blanket prohibition against termination of gas service by utility to any residential consumer during winter months was beyond scope of home rule powers (Ill. Const. 1970, Art. VII, Sec.6(a)).

Chicago Bar Association v. County of Cook
79 Ill. Dec. 824
464 N.E.2d 728
Cook County did not have authority under its constitutional home rule powers, to enact ordinance altering board of appeals for property tax assessment by adding a third commissioner, staggering terms of present commissioners, changing manner of election and providing for Board to elect Chairman (Ill. Const. 1970, Art. VII, Sees. 4(c), 6(a), (f) and (m)).

People ex rel. Barnardi v. City of Highland Park
(2nd Dist. App. Ct. No. 84-417)
Votes of City Council were acts taken by governing board of home rule unit, as an assertion of autonomy and independence from State control granted by Article .VII, § 6 of 1970 Illinois Constitution to supersede requirements of Illinois Prevailing Wage Act (ch. 48, par. 39s-1 et seq.).

Determination of wages for public construction project is a function pertaining to "government and affairs" as contemplated by Illinois Constitution Article VII, § 6(a), hence, city not bound by Prevailing Wage Act.

Leek v. Michaelson
84 Ill. Dec. 770
472 N.E.2d 1166
Home rule ordinance provisions conflicting with State Election Code were invalid, but village was constitutionally empowered to require 50% majority vote for election to village office and to implement run-off election system. Leave to appeal denied.

Sanders v. City of Springfield
85 Ill. Dec. 710
474 N.E.2d 438
Home rule ordinance conditioning employment of policemen on membership and participation in pension fund was not pre-empted by Illinois Civil Service Act. (ch. 24, par. 10-1-1 et seq.).

Webster v. City of Chicago
88 Ill. Dec. 131
478 N.E.2d 446
Home rule transaction tax ordinance which imposes tax on lease or rental of personal property was not in violation of constitutional provision that home rule units have only powder that General Assembly may provide by law to license for revenue or impose taxes on occupations. (Ill. Const. 1970, Art. VII, Sec. 6(e)).

November 1985 / Illinois Municipal Review / Page 17

Royal Liquor Mart, Inc. v. City of Rockford
88 Ill. Dec. 872
479 N.E.2d 485
Voter referendum repealing city's home rule powers did not repeal sales tax enacted pursuant to those powers where tax was pledged to, supported valid obligation and was passed at time when municipality had authority to levy such tax.

Romanik v. Village of Valmeyer
80 Ill. Dec. 843
466 N.E.2d 295
Ordinance providing for police chief appointment did not create "office" of police chief and thus chief, as employee, was not entitled to procedural protections afforded to "officials" by village ordinances.

People, ex rel. City of Kankakee v. Morris
81 Ill. Dec. 718
467 N.E.2d 589
Under statute providing vacancy occurs in office of alderman by reason of conviction of disqualifying crime, convicted alderman could be ousted from office for a felony theft conviction, even though he was sentenced to probation rather than to prison (ch. 24, par. 3-4-14).

Taylor v. Board of Trustees of Police Pension
81 Ill. Dec. 273
466 N.E.2d 1075
Police chief's responsibilities of large municipality could not be classified as part-time for pension purposes under statute which excluded part-time policemen.

O'Donnell v. City of Chicago
81 Ill. Dec. 849
467 N.E.2d 971
Public employee's action against municipal employer, for injuries incurred in the course of employment during working day, was barred by Illinois Pension Code where municipality enacted an ordinance pursuant to the Pension Code providing for payment of medical care and hospital treatment in such an event. (ch. 108 1/2, par. 22-307). Leave to appeal denied.

Kaiser v. Dixon
82 Ill. Dec. 275
468 N.E.2d 822
Ordinance granting Village Police Chief rule-making authority did not include authority for discharge of non-sworn employee. Leave to appeal denied.

Kalb v. Village of Oaklawn
83 Ill. Dec. 848
470 N.E.2d 1268
Retired firefighter was entitled to accumulated unused sick leave compensation based upon 120 days of accumulated sick leave at 8 hours per day despite the fact that firefighter worked a 24-hour day with 48 hours off.

City of Springfield v. Roard of Education Com'rs of City of Springfield
85 Ill. Dec. 508
473 N.E.2d 1313
Authority to appoint for balance of unexpired term occurs only if interim election is not required under Municipal Code. (ch. 24, par. 3-2-7 and par. 4-3-4.)

Mulligan v. Village of Bradley
86 Ill. Dec. 650
475 N.E.2d 1029
Position of Village Administrator offered to Village President created a conflict of interest in violation of Act prohibiting pecuniary interests in contracts and also Corrupt Practices Act (ch. 24, par 3-14-4, ch., 102, par, 3).

Sinnock v. Beardstown Rd. of Fire and Pol. Com'rs
87 Ill. Dec. 31
476 N.E.2d 492
Former Chief of Police who resigned and resumed duties as officer continued to accumulate seniority in rank as officer while serving as Chief of Police, for furlough purposes (ch. 24, par. 10-2.1-4).

Ligenza v. Village of Round Lake Beach
88 Ill. Dec. 579
478 N.E.2d 1187
Requirement of prior appropriation was a condition precedent to validity of multi-year collective bargaining agreement entered into between Village and police organization, since it was a contract dealing with expenditure of general funds (ch. 24, par. 8-1-7).

Beard v. Roard of Police Commissioners
86 Ill. Dec. 4
474 N.E.2d 918
Administrative Review Act applies to promotion of police officers under section 10-2.1-15 of Municipal Code and exhaustion of administrative remedies is required prior to commencing lawsuit challenging promotion of police officers (ch. 24, par, 10-2.1-15).

Sellards v. Rd. of Polling Meadows Firemans Pension Fund
88 Ill. Dec. 515
478 N.E.2d 1123
Board of Trustees of Firemen's Pension Fund acted properly when it reduced disability pension benefits by amount of the payments received under Workers' Compensation Act (ch. 108 1/2, par. 4-143.)

Village of Oak Wood Hills v. Diamond
80 Ill. Dec. 550
465 N.E.2d 662
Ordinance regulating speed limit within Village held invalid for failure to comply with statutory requirement that difference in speed limit between adjacent altered speed zones shall not be more than 10 MPH.

Page 18 / Illinois Municipal Review / November 1985

People, ex rel. Fahner v. Chicago Transit Authority
82 Ill. Dec. 536
468 N.E.2d 1316
Ordinance of Chicago Transit Authority which attempted to prevent unclaimed property from passing to State pursuant to Uniform Disposition of Unclaimed Property Act held invalid.

Radcliff v. City of Berwyn
84 Ill. Dec. 348
472 N.E.2d 98
Ordinance prohibiting parking of inoperable vehicles upon private property was not unconstitutionally vague.

Coles-Moultrie Electric Co-op v. Commerce
87 Ill. Dec. 311
476 N.E.2d 1303
Municipal franchises which permitted both electric public utility and electric cooperative to serve area which had been annexed was not a manifest abuse of municipal franchise power.

City of Tuscola v. D & B Refuse Service, Inc.
86 Ill. Dec. 419
N.E.2d 633
Resolution is inadequate to accomplish that which must be done by means of an ordinance; thus exclusive contract ratified by resolution for garbage collection service did not prohibit collection by firms not under the contract in absence of ordinance precluding other businesses from garbage collection within the city.

Great Plains Resources v. City of Benton
82 Ill. Dec. 807
469 N.E.2d 341
Municipality prohibited from raising revenue by exercise of its police power by imposing license and royalty fees for oil well drilling in absence of authority from General Assembly.

Buffalo, Dawson, Mechanicsburg Sewer Commission v. Boggs
83 Ill. Dec. 523
470 N.E.2d 649
Sewer commission's ordinance requiring all property owners in district to connect all sewage disposal systems to those of the commission was a valid exercise of commission's power under Municipal Code. (ch. 24, par. 11-136-1 et seq.) Leave to appeal allowed.

Greater Peoria San. and Sew. Disposal Dist. v. Kellstedt
86 Ill. Dec. 70
474 N.E.2d 1267
Ordinance providing sewer charges held invalid to extent it fails to permit credit for substantial non-sanitary services.

Mt. Prospect S. Bank v. Village of Kirkland
82 Ill. Dec. 69
467 N.E.2d 1142
Rational basis existed for excluding mobile home park from receiving garbage collection service under contract between village and garbage collector since park had more character of commercial property which generates greater amount of refuse than residential property.

Haeflinger v. City of Wood Dale
84 Ill. Dec. 832
472 N.E.2d 1228
Municipality was not equitably estopped from collecting past due sewer "user fees" for past 20 years of use by land owner.

Weiner v. Forest Preserve District of Cook County
81 Ill. Dec. 484
466 N.E.2d 1286
Judgments confirming special assessments against a municipal or public corporation cannot create a lien upon the property, thus, "special assessment liens" held by Village on property of public agency were not liens available for purchase by private citizen.

Village of Oaklawn v. Rosewell
83 Ill. Dec. 904
471 N.E.2d 203
Statute authorizing collection of penalty for delinquent real estate taxes does not violate constitutional provision forbidding payment of local expenses from fees collected. Leave to appeal allowed.

Burnett v. Donath, et al.
82 Ill. Dec. 239
468 N.E.2d 501
Passenger injured in auto accident failed to state negligence claim absent allegation that traffic controls were defective and accident could have been prevented if municipality had provided left turn lanes at intersection. Leave to appeal denied.

Bessie and Juanita McCottrell v. City of Chicago
(Ill. App. 1st Dist. No. 84-2149)
Municipal corporation held liable for employees' tortious acts even where employees were not named in plaintiffs' cause.

Galuszynski v. City of Chicago
86 Ill. Dec. 581
475 N.E.2d 960
Municipality's failure to promptly respond to "911" emergency call did not state a cause of action and failed to allege existence of "special duty" exception to Tort Immunity Act. (ch. 85, par. 4-102).

Marshall v. Ellison
87 Ill. Dec. 704
477 N.E.2d 830
Municipality owed no special duty to intoxicated individual who was struck by truck while walking along

November 1985 / Illinois Municipal Review / Page 19

roadway after police officers stopped enroute to an emergency call and instructed individual to get off roadway.

Antiporek v. Village of Hillside
(1st Dist. App. Ct. No. 84-411)
Municipality's membership in a risk pool of self-insurers does not affect a waiver of provisions under the Tort Immunity Act.

Palladini v. City of East Peoria
89 Ill. Dec. 345
480 N.E.2d 530
Under Tort Immunity Act legislature did not intend that a plaintiffs contributory negligence would limit the duty of municipalities (ch. 85, par. 3-102(a)).

Thompson v. City of Chicago
83 Ill. Dec. 292
470 N.E.2d 47
Police officer who backed his vehicle away from rock and bottle throwing crowd was not in act of "execution or enforcement of any law" within meaning of local governmental and governmental employees Tort Immunity Act (ch. 85, par. 2-202). Leave to appeal allowed.

City of Moline v. Pollution Control Bd.
88 Ill. Dec. 415
478 N.E.2d 906
Imposition of fine against municipality for operating sewage treatment plant in violation of Environmental Protection Act was improper where violations were corrected before initiation of enforcement proceedings and penalty would not bring about additional compliance.

Village of North Brook v. County of Cook
81 Ill. Dec. 413
466 N.E.2d 1215
Village had standing to challenge proposed use of property adjacent to its border.

Lakin v. City of Peoria
84 Ill. Dec. 837
472 N.E.2d 1233
Zoning provision requiring property owner to obtain consent from adjacent property owners for Two-Family Dwelling was unconstitutional.

People ex rel. Village of Hazelcrest v. Village of Homewood
88 Ill. Dec. 111
478 N.E.2d 426
Annexation by first village was void to extent that it purported to annex portion of street which bordered property of second village, therefore subsequent annexation by second village was valid as annexation of contiguous property.

Wilmette Park District v. Village of Wilmette
89 Ill. Dec. 506
480 N.E.2d 1249
Park District not immune from municipal zoning ordinance requirements when performing statutory functions. Cooperative control requires district comply with zoning provisions and request special use exemptions in proper cases.

Sweitzer, et al. v. City of O'Fallon
(5th Dist. App. Ct. No. 5-84-0320)
Zoning ordinance excluding all manufactured housing from residential zoning districts held valid where City had established three mobile home parks and three mobile home subdivisions.

Chicago Sch. Fin. Auth. v. Chicago City Council
84 Ill. Dec. 668
472 N.E.2d 805
Statute authorizing school finance authority to direct city to provide for tax levy for payment of bonds issued to finance schools is constitutional and not a violation of home rule powers.

Dunne v. County of Cook
(Ill. Sup. Ct. Docket No. 60178)
Ordinance reducing from four-fifths to three-fifths the majority necessary to override veto by president of County Board is unconstitutional. Such change can only be accomplished by referendum.

Kalodimos v. Village of Morton Grove
83 Ill. Dec. 308
470 N.E.2d 266
Home rule ordinance which prohibited possession of operable hand gun within village did not violate State constitutional right to bear arms. Home rule is predicated on assumption that problems of local government be open to local solution to meet local needs free from veto by voters of other parts of the State who might disagree with particular approach advanced by representatives of locality involved or fail to appreciate local perception of the problem.

Thaxton v. Walton
88 Ill. Dec. 624
478 N.E.2d 1350
Employee who obtained judicial ruling for wrongful discharge may not have back pay reduced by amount paid to substitute employee hired to replace him during period of wrongful suspension and discharge.

Schmolke v. Highland Butterfield, Inc.
83 Ill. Dec. 927
471 N.E.2d 226
Villages are not included in provision of municipal

Page 20 / Illinois Municipal Review / November 1985

code which authorizes corporate authorities of a city to remove cemetery on same basis as may a town under Cemetery Act and thus that statute could not be considered authority for Village to exercise such power (ch. 24, par. 11-51-1).

TAXATION

Chicago Gravel Company v. Rosewell
83 Ill. Dec. 164
469 N.E.2d 1098
Once property is defined and identified by taxing body and has been assessed, levied, billed and taxes paid thereon, taxing authorities cannot recapture more taxes merely because assessor made clerical error in taxing formula.

Bd. of C. of Wood Dale P.L. v. DuPage County
83 Ill. Dec. 224
469 N.E.2d 1370
Decision of Illinois Supreme Court in Wood Dale I holding unconstitutional county's practice of retaining interest on investments of tax money should be applied prospectively from May 27, 1983, the date the opinion was filed in Wood Dale I.

Village of Pawnee v. Johnson
83 Ill. Dec. 219
469 N.E.2d 1365
Municipalities are entitled to interest income on monies held by State Treasurer, pursuant to Municipal Retailers' Occupation Tax Act but not entitled to interest on funds already transferred to general revenue fund (ch. 24, par. 8-11-1; ch. 85, par. 902).

Johnson v. Partee
85 Ill. Dec. 345
473 N.E.2d 944
Municipality which imposed utility tax on customers was exempt from utility's 3% fee charged to customers to cover cost of collecting the tax (ch. 24, par. 8-11-2).

FEDERAL COURT DECISIONS

OFFICERS & EMPLOYEES

Hill v. Longini
767 F. 2d 332
Attorney who represented Village police officers and civil rights action was entitled to award of attorneys fees.

Tomzak v. City of Chicago
765 F. 2d 633
Second in rank under city water department was not a position exempt from prohibition against patronage dismissal.

Electronic Relays Pvt. Ltd. v. Pascente
610 F. Supp. 648
Two year State limitations period for action for treble damages applied to civil RICO action.

Borek v. Town of McLeansboro
609 F. Supp. 807
(D.C. Ill.)
Attorney's complaint that town supervisor hit him as he attempted to leave meeting stated Section 1983 claim.

Shakman v. Democratic Organization of Cook County
607 F. Supp. 1086
(D.C. Ill.)
Judicial decree concerning hiring for non-exempt county jobs would not be amended in any major way since it simply prohibits hiring which gives political recommendations more weight than other relevant recommendations (including recommendations of rival political groups).

Strauss v. City of Chicago
760 F. 2d 765
(7th Cir. Ill.)
Complaint against city for adopting custom of hiring police officers with history of brutality failed to state claim.

Gutierrez v. City of Chicago
605 F. Supp. 973
(D.C. Ill.)
Probationary employees sufficiently alleged constitutionally protected property interest in continued employment.

Grant v. City of Chicago
594 F. Supp. 1441
(D.C. Ill.)
Ordinance authorizing immobilization of automobiles for outstanding traffic violations did not violate Equal Protection Clause or Due Process requirements.

Planned Parenthood Ass'n./Chicago Area v. Chicago Transit Authority
(7th Cir. Ill.)
(No. 84-2518)
District court's injunction enjoining CTA from refusing to sell advertising to Planned Parenthood affirmed as CTA advertising system had become a public forum and CTA has no policy which would exclude the submitted advertisements.

Hintz v. Jamison
743 F. 2d 535
(7th Cir. Ill.)
Township's immunity for alleged improper road signing was waived by township's insurance policy.

November 1985 / Illinois Municipal Review / Page 21

Jackson v. Byrne
738 F. 2d 1443
(7th Cir. Ill.)
City could not be held liable in civil rights action for deaths of two children in fire which occurred during municipal firefighters strike.

Foster v. Kusper
587 F. Supp. 1194
(D.C. Ill.)
Illinois Election Statute requiring write-in candidate to receive votes equalling or exceeding signatures required on nominating petition held unconstitutional.

Cinivision Corp. v. City of Burbank
745 F. 2d 560
City violated promoter's First Amendment rights by disapproving proposed concerts on the basis of the content of the performer's expression and other arbitrary factors.

Eames v. City of Logan, Utah
762 F. 2d 83
Although no property interest in job warranted due process protection, there existed liberty interest and opportunity to name-clearing hearing for government employee allegedly stigmatized resulting from discharge because there was danger of foreclosure to community, due to derogatory reasons for being fired.

New York State Commission on Cable Television v. FCC
FCC has authority to restrict state and local regulation of pay television service of satellite master antenna television systems.

TORT IMMUNITY

Kolar v. County of Sangamon of State of Illinois
756 F. 2d 564
Illinois statute subjecting local government entity to liability for tort judgments or settlements against an employee for actions undertaken in scope of employment, by virtue of affording government employees indemnity, operates as a waiver of governmental entity's immunity from liability for punitive damage awards in civil right actions, (ch. 85, par. 9-102)

ANTITRUST

Town of Hallie, et al. v. City of Eau Claire
105 S.Ct. 1713
Municipality's anti-competitive activities were protected by the State action exemption to federal antitrust laws when the activities were authorized, but not compelled, by the State and although the State did not actively supervise the anti-competitive conduct.

OFFICERS & EMPLOYEES

Garcia v. San Antonio Metropolitan Transit Authority, et al.
53 U.S.L.W. 4135
105 S.Ct. 1005
Public employers are not immune from minimum wage and overtime requirements of the Fair Labor Standards Act. (29 U.S.C.A., sec. 201 et seq.)

Cleveland Board of Education v. Loudermill, et al.
105 S.Ct. 1487
While legislature may elect not to confer a public interest in public employment, it may not constitutionally authorize the deprivation of such an interest once conferred without appropriate procedural safeguards.

Brandon v. Holt
105 S.Ct. 873
Although lawsuit was filed against director of city's police department in his official capacity under civil rights act the lawsuit was in effect against the City for purposes of imposing on it liability for the judgment, though City was not named as defendant.

TORT IMMUNITY

Sedima, S.P.R.L. v. Irnrex Co., Inc., et al.
105 S.Ct. 3275
Racketeer Influence and Corrupt Organizations Act gives no obvious indication that a private treble damages action can proceed only after criminal conviction.

Also, there is no requirement that plaintiff in a private action establish a "racketeering injury" as opposed to an injury resulting from predicate acts themselves.

TORTS

American National Bank & Trust Company of Chicago v. Haroco, Inc.
105 S.Ct. 3291
Civil claim for treble damages under RICO does not require that plaintiff have suffered damages by reason of defendant's offenses, rather, injury from those offenses alone is sufficient.

City of Oklahoma City v. Tuttle
105 S.Ct. 2427
City held not liable under civil rights action for isolated act of police misconduct or fact that municipal "policy" might lead to police misconduct.

ZONING

City of Cleburne, Texas v. Cleburne Living Center
105 S.Ct. 3249
Requiring special use permit for proposed group home for mentally retarded violated equal protector clause in absence of any rational basis in record demonstrating that home would pose any special threat to city's legitimate interests.

Page 22 / Illinois Municipal Review / November 1985

The following cases were denied certiorari by the United States Supreme Court during the 1984-85 term.

Brontel, Ltd. v. City of New York
(No. 84-101)
Municipal rent control regulations on private but not municipal properties are in furtherance or implementation of clearly articulated and affirmatively expressed State policy, and thus come within State action exemption to antitrust laws.

Campbell v. Purist County, Georgia
(84-1161)
Discharged at-will public employee does not have property interest in continued employment but does have protective liberty interest in reputation; post-termination hearing is sufficient to comport with due process requirements, where alleged deprivation is of liberty interest in reputation.

Golden State Transport Corp. v. City of Los Angeles
(No. 84-378)
City is immune from antitrust liability for refusing to renew taxing company's license to operate; city need not show active State supervision of regulation to qualify for immunity under antitrust laws.

Gold Cross Ambulance Co., Inc. v. City of Kansas City
(No. 83-138)
Municipal single-operator ambulance system which provided all of city's emergency and non-emergency ambulance service pursuant to State authorization and clearly articulated and affirmatively expressed policy to displace free competition in ambulance business was shielded from Federal and State antitrust liability.

Central Iowa Refuse Systems, Inc. v. DeMoines Metropolitan Area Solid Waste Agency
(No. 83-825)
Municipal solid waste facility was protected under antitrust immunity even though legislature did not specifically contemplate that municipal agency, in constructing and operating landfill, would have exclusive right to dispose of solid waste produced in municipal area or would engage in practices in restraint of trade to guarantee its financial vitality.

85-017 Successful referendum pursuant to Illinois Constitution Article VII, Section 7, permits non-home rule municipality authority to determine manner of selection of its officers including whether they should be elected on a non-partisan basis.

85-013 Resident bidders may be allowed preference when contract is awarded in accordance with purchasing act. Ill. Rev. Stats. 1983, ch. 127, par. 132.6, and does not impair interstate commerce, deny equal protection, or infringe upon privileges and immunities of citizens from other states when non-resident bidders from other states grant preferences to their resident bidders.

85-015 Office of Park District President is incompatible with office of City Alderman.

85-014 Proposed improvements in manufacturing facility which, if constructed, would constitute expansion of previously existing facility would render property eligible for tax abatement (Ill.Rev.Stat. 1983. ch. 120, par. 643).

85-002 Municipalities must enforce provisions of ch. 95 1/2, par. 11-1301.3 with respect to properly posted handicapped parking spaces located on private property; however, municipalities including home rule units may not impose different penalties for unauthorized use of handicapped parking spaces.

RICO in the Seventh Circuit: Criminal shadows on civil litigation. Robert J. Labate,73 Ill. Bar J. 546 (1985).

Zoning and Land Use Symposium. 60 Chicago-Kent Law Review 1 (1984).

The Illinois Personnel Records Statutes: New Rights for Employees, New Risk for Employers. Michael J. Leech, 73 Ill. Bar J. 386 (1985).

Private RICO Actions in Illinois: When Has The Statute Run? Charles R. McKirdy, 73 Ill. Bar J. 284 (1985).

Collective Bargaining for Public Employees: An Overview of Illinois' New Act. Michael Jenkins, Southern Illinois U.L.J. 483 (1983).

Changing Configurations of Antitrust Law: Judge Posner's Applications of His Economic Analysis to Antitrust Doctrine. Comment 32 DePaul L. Rev. 839 (1983).

Developments in the Law of Illinois: Home Rule. Survey 17 John Marshall L. Rev. 613 (1984).

Political Patronage in Public Contracting. Comment 51 U. Chicago L. Rev. 518 (1984).

Wrongful Termination: A New Common Law Remedy for Employees-At-Will? John R. Heying, 72 Ill. Bar J. 584 (1984).

Federalism, Antitrust and Illinois Home Rule. Comment, Southern Illinois U.L.J. 31 (1983).

November 1985 / Illinois Municipal Review / Page 23