Pay Now Illinois

Legal Action

FEBRUARY UPDATE -- February 9, 2017:

FY17 ST. CLAIR COUNTY LAWSUIT

Pay Now Illinois today filed a complaint in the Circuit Court of St. Clair County, asking to be paid for services delivered under contracts dating back to the start of fiscal year 2017, beginning on July 1, 2016. Read the complaint.

Read our Reply in Support of our Motion for Preliminary Injunction, filed on May 10, 2017

Read Defendants' Combined Memorandum of Law in Support of their Motion to Dismiss, filed on April 19, 2017

Read our First Amended Complaint, filed on March 13, 2017

Read the Motion for Preliminary Injunction, filed in St. Clair County Circuit Court on February 21, 2017

Read the Motion to File a Brief in Excess of 10 Pages, filed in St. Clair County Circuit Court on February 21, 2017

Read the Supporting Brief and Exhibits, filed in St. Clair County Circuit Court on February 21, 2017

Read the list of plaintifs who are part of the St. Clair County filing


APPEAL

Read our Reply Brief to the Attorney General, filed on March 10, 2017

Read the State's Appellate Brief, filed on February 24, 2017

SEPTEMBER UPDATE: Pay Now Illinois is appealing the August 31 decision by the Circuit Court of Cook County to deny plaintiffs’ motions for preliminary and permanent injunction and grant the defendants’ motions to dismiss the Pay Now Illinois lawsuit against the Governor, Comptroller, and seven state department heads.  

Click here to read the list of plaintiffs who are appealing the August 31 court decision, and here to read the Appellants' Brief to the First Judicial Circuit of the Illinois Appellate Court, December 20. 


ORIGINAL LAWSUIT

Our suit is against Governor Bruce Rauner, Comptroller Leslie Munger and the directors of seven statewide agencies seeking immediate payment in full for services we have delivered since July 1, 2015.

Our contracts are signed and valid. We have provided services and performed according to those contract terms. Now we need to be paid. That is just good business -- because no one should be forced to work for nothing.

The unprecedented nature of this lawsuit claims breach of contract and violation of our constitutional rights to due process of law.

Throughout the fiscal year the State has benefitted from the labor and work of the human and social service agencies that are meeting the essential needs of vulnerable populations throughout Illinois. It's time to get back to good business practices; the State must pay for the benefits it is receiving.

"Working for free" is taking a financial toll on our agencies and companies; some may have to close their doors. And the real loser will be the residents of Illinois. 

Click here to view the Appellate Court order granting the Defendants a 31-day extention to file their appellate brief, January 31, 2017

Click here to read the Appellate Court's Denial of Motion to Expedite Appeal, January 5, 2017

Click here to read the Appellants' Motion to Expedite Appeal, December 23

Click here to read the Appellants' Brief to the First Judicial Circuit of the Illinois Appellate Court, December 20

Click here to read the State's Response to the Motion for Direct Appeal, October 26

Click here to read the Motion for Direct Appeal to Supreme Court, October 20

Click here to read the Request for Preparation of Record on Appeal, October 4

Click here to read the Third Amended Notice of Appeal, September 30

Click here to read the First Amended Notice of Appeal, September 15

Click here to read the list of Plaintiffs who are appealing the August 31 court decision

Click here to read the State's Reply in Support of their Motion to Dismiss, August 25

Click here to read the Plaintiffs' Combined Memorandom in Response to the State's Motion to Dismiss, August 19


The following exhibits are referenced in the case:

Exhibit 1 is related to the 2015 AFSCME case, August 19

Exhibit 2 is related to the Supreme Court ruling in July 2015, August 19

Exhibit 3 is from the Department of Aging saying the Stop Gap is not a budget, August 19


Click here to read the State's Motion to Dismiss, August 12

Click here to read the Third Amended Complaint, July 20

Click here to read the Renewed Motion for Preliminary Injunction, July 20

Click here to read the Motion for Leave to File the Third Amended Complaint, July 12

Click here to read the July 6 Motion from the Defendants

Click here to read the June 17 Amended Complaint

Click here to read The Shriver Center's Amicus Brief on behalf of 19 organizations affected by payment delays being challenged by Pay Now Illinois.

Click here to read the May 25 Motion to file the Amended Complaint

Click here to read the May 25 Amended Complaint

Click here to read the lawsuit filed on May 4


www.paynowillinois.org

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