Provena Health (Provena) (plaintiff), a subsidiary of a larger Catholic-based healthcare entity located in Illinois and which operated Provena Covenant Medical Center (PCMC), was denied charitable tax exemption status under state law in 2002 by the Director of the Illinois Department of Revenue (defendant) despite having been granted the exemption in previous years. The Director determined that Provena failed to meet the state’s statutory “charitable ownership” and “charitable use” requirements. Upon review, an Illinois appellate court upheld the Director’s decision. Provena appealed. The Illinois Supreme Court granted certiorari to review.