Illinois Supreme Court Finds City PSEBA Ordinance Invalid
The Illinois Supreme Court issued an opinion in an appeal of a case filed by a firefighter union against an Illinois City that challenged the City's PSEBA ordinance. Specifically, the union had argued that the City's definition of "catastrophic injury" in its ordinance was inconsistent with the PSEBA statute and the Illinois Supreme Court's definition of that term in the case Krohe v. City of Bloomington. The circuit and appellate courts had ruled in favor of the union and the City appealed to the Illinois Supreme Court. Today, the Illinois Supreme Court issued its decision affirming the ruling in favor of the union, finding the City's definitions in its PSEBA ordinance of "catastrophic injury" and "injury" to be inconsistent with the PSEBA statute. International Assoc. of Firefighters v. City of Peoria, 2022 IL 127040.
In 2018, the City passed an ordinance amending its City Code to define "catastrophic injury" for purposes of determining whether an officer was entitled to benefits under the Public Safety Employee Benefits Act (PSEBA) to add a requirement that an officer show that his or her on-duty injury prevented the officer from "performing any gainful work." The local firefighters union filed suit against the City, claiming that the City had no authority to modify the definition of "catastrophic injury" and that the definition was inconsistent with the PSEBA statute that does not include that phrase as well as the Illinois Supreme Court's interpretation of "catastrophic injury" in the Krohe decision. The union also challenged the ordinance's definition of "injury" as being inconsistent with the PSEBA statute. The City defended its ordinance and definitions, arguing that it had the authority to define these terms based on its home rule powers. After both the circuit court and appellate court ruled against the City, the City appealed to the Illinois Supreme Court.
The Illinois Supreme Court held that the City's definition of "catastrophic injury" that added the requirement that an officer show that the officer's disability prevented the officer from "performing gainful work" was inconsistent with the PSEBA statute. The Court found that this added language impermissibly disqualified offices who might otherwise be entitled to benefits under the PSEBA statute. The Court also found the City's definition of "injury" to be inconsistent with the PSEBA statute as it would also disqualify those who might otherwise meet the requirements of the PSEBA statute. In sum, the Illinois Supreme Court determined that the City's PSEBA ordinance was not a valid exercise of home rule authority because its definitions were inconsistent with the requirements of the Act and, therefore, preempted.
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