Board of Education of Maine Township v. State Board of Education

The Illinois legislature (the legislature) enacted the State Mandates Act (the act), which required the state to reimburse units of local government, including school districts, for the added costs of state-imposed mandates. The act stated that a mandate was required to be accompanied by an appropriation of state funds. However, a mandate was excluded from the reimbursement requirement if the mandate met at least one of the five exclusions described in the act. The legislature was required to state whether any of the five exclusions were applicable to a mandate. Further, the act stated that the legislature could prepare a fiscal note detailing the financial impact of a mandate, but this note was not mandatory. The legislature enacted the Nurses’ Pay Bill (the bill), which raised nurses’ salaries to the level of teachers’ salaries. Local school boards were mandated to raise the nurses’ salaries. The bill was not accompanied by an appropriation of state funds and also lacked a fiscal note. Although the bill made no reference to any of the five exclusions, the bill declared that reimbursements were not required by the act. The Board of Education of Maine Township High School District 207 (plaintiff) (Maine Township) brought suit against the State Board of Education (defendant), contending that the bill violated the act. The trial court held that the bill was not void in its entirety for lack of a fiscal note. The trial court also held that the bill was enforceable against school districts without an appropriation of state funds to cover the cost of the mandate. Maine Township appealed.