Suarez v. Metro-East Sanitary District

2020 IL App (5th) 200012-U
CourtAppellate Court of Illinois
DecidedJanuary 16, 2020
Docket5-20-0012
StatusUnpublished

This text of 2020 IL App (5th) 200012-U (Suarez v. Metro-East Sanitary District) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Suarez v. Metro-East Sanitary District, 2020 IL App (5th) 200012-U (Ill. Ct. App. 2020).

Opinion

NOTICE 2020 IL App (5th) 200012-U NOTICE Decision filed 01/16/20. The This order was filed under text of this decision may be NO. 5-20-0012 Supreme Court Rule 23 and changed or corrected prior to may not be cited as precedent the filing of a Petition for by any party except in the Rehearing or the disposition of IN THE limited circumstances allowed the same. under Rule 23(e)(1).

APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ________________________________________________________________________

MICHAEL SUAREZ, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) St. Clair County. ) v. ) No. 19-MR-324 ) METRO EAST SANITARY DISTRICT, ) Honorable ) Julie K. Katz, Defendant-Appellant. ) Judge, presiding. ________________________________________________________________________

PRESIDING JUSTICE WELCH delivered the judgment of the court. Justices Moore and Boie concurred in the judgment.

ORDER

¶1 Held: The circuit court did not abuse its discretion in issuing a temporary restraining order (TRO) after notice and a hearing where the plaintiff taxpayer demonstrated that he had a certain and clearly ascertainable right in ensuring that the Metro-East Sanitary District complied with the recent amendment to section 3-1 of the Metro-East Sanitary District Act of 1974 (Pub. Act 101-308 (eff. Jan. 1, 2020) (amending 70 ILCS 2905/3-1)), that he would suffer irreparable harm without the protection of a TRO, that he had a substantial likelihood of success on the merits in the underlying action, and a balancing of the equities favored issuing the TRO.

¶2 This interlocutory appeal concerns a recent amendment to section 3-1 of the

Metro-East Sanitary District Act of 1974 (Act) (Pub. Act 101-308 (eff. Jan. 1, 2020)

(amending 70 ILCS 2905/3-1)), which sets forth the procedures for appointment of

1 commissioners to the Metro East Sanitary District’s (MESD) Board of Commissioners

(Board). On December 27, 2019, the plaintiff, Michael Suarez, who is a taxpayer of the

MESD, filed a complaint in the circuit court of St. Clair County for a declaratory

judgment, seeking a declaration that the recent amendment to section 3-1 was valid and

mandatory upon the defendant, the MESD. On January 6, 2020, Suarez filed a motion

for temporary restraining order (TRO), requesting that the circuit court (1) order the

MESD to comply with section 3-1 of the Act as amended, which included recognizing

the appointment of Scott Oney as a commissioner to the Board, and (2) prohibit the

MESD from taking any further action in violation of section 3-1 of the Act. Thereafter,

the court granted Suarez’s request for a TRO. The MESD filed a timely notice of

interlocutory appeal pursuant to Illinois Supreme Court Rule 307(d) (eff. Nov. 1, 2017).

For the following reasons, we affirm the circuit court’s granting of the TRO.

¶3 I. BACKGROUND

¶4 Suarez resides in Fairmont City, Illinois, and is a resident/taxpayer of the MESD.

The MESD, as a special district, is a corporate and politic body that was organized and

that exists under the Act (70 ILCS 2905/1-1 et seq. (West 2018)). The MESD is

governed by the Board, which consists of five commissioners. 70 ILCS 2905/3-1 (West

2018). The MESD has a contractual agreement with Granite City to purchase wastewater

treatment services from the Granite City Wastewater Treatment Plant at rates established

by the Granite City Regional Treatment Board. The mayor of Granite City is an active

participant in the rate negotiations.

2 ¶5 On August 9, 2019, Illinois Public Act 101-308 was enacted, which amended

section 3-1 of the Act with regard to the appointment of commissioners to the Board.

Specifically, the amendment instructed as follows:

“Beginning on the effective date of this amendatory Act of the 101st General Assembly, the mayor, or his or her designee, of the largest municipality in the county having the greater equalized assessed valuation of the district shall be an ex officio commissioner with a right to vote. If there is not a vacant commissioner position from the county having the greater equalized assessed valuation on the effective date of this amendatory Act of the 101st General Assembly, then the term of the last appointed commissioner from that county is terminated on the effective date of this amendatory Act of the 101st General Assembly.” Pub. Act 101-308 (eff. Jan. 1, 2020) (amending 70 ILCS 2905/3-1).

¶6 On December 27, 2019, Suarez filed a complaint for declaratory judgment, which

alleged the following: that, on November 22, 2019, the Board held a special meeting; and

that, based on the public notice from that meeting, 1 it appeared that the MESD was

preparing to challenge Public Act 101-308 and was also attempting to modify the bylaws

to change the number of Board commissioners required to constitute a quorum, which

was contrary to section 1.02 of the Open Meetings Act (5 ILCS 120/1.02 (West 2018)).

¶7 On January 2, 2020, Granite City Mayor Ed Hagnauer named Scott Oney, a

MESD resident, as his designee to sit on the Board with all rights and powers designated

under section 3-1 as amended. In response, on January 3, 2020, the president of the

MESD Board sent a letter to Mayor Hagnauer, advising that his designation of a

commissioner was invalid as a matter of law and that the Board would not recognize that

appointment for the reasons “set out in the attached lawsuit.” Attached to the letter was a

complaint for declaratory judgment filed on December 23, 2019, by the MESD against

1 Suarez asserted that the minutes of this November 22, 2019, meeting were not made public. 3 Mayor Hagnauer in the circuit court of Madison County. The complaint alleged that

Granite City, Illinois, interpreted the section 3-1 amendment to mean that, beginning

January 2020, Mayor Hagnauer, as the mayor of Granite City, could assume an ex officio

commissioner position on the Board with a right to vote; that Illinois has adopted the

doctrine of incompatibility of offices, which precludes simultaneous tenure in two public

offices where the duties of the two offices conflict; and that there is an incompatibility

between the offices of the mayor of Granite City and a board member of the MESD.

Thus, the complaint contended that there is a conflict of interest which prevented the

same individual from holding both positions and that, if Mayor Hagnauer was seated as a

MESD commissioner or was allowed to designate a MESD commissioner, there would

be a clear violation of long-standing and well-developed Illinois law.

¶8 On January 6, 2020, Suarez filed a motion for TRO within the St. Clair County

declaratory judgment action. In the motion for TRO, Suarez requested that the trial court

issue a TRO pursuant to section 11-101 of the Code of Civil Procedure (Code) (735

ILCS 5/11-101 (West 2018)), requiring the MESD to comply with section 3-1 of the Act

as amended by recognizing Mayor Hagnauer’s designation of an MESD commissioner

and prohibiting the MESD from taking any action in violation of the amended Act

pending resolution of his complaint for declaratory judgment.

¶9 Suarez alleges that he had a clearly ascertainable right that needed protection in

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2020 IL App (5th) 200012-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/suarez-v-metro-east-sanitary-district-illappct-2020.