A Publication of Ancel, Glink, Diamond, Bush, DiCianni & Krafthefer, P.C.
Autumn 2000

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Is Your Municipality's Political Sign Ordinance Enforceable?
Is Your Zoning Board Afraid of Variances?
Student Invocation at School Football Game is Unconstitutional
Can Your Park District Benefit from a Corporate Sponsorship?
What You Don't Know Could Cost You Grant Money
Terminiating a Municipal Officer?

Firm News
'Round 'Round, Get Around, We Get Around

Is Your Municipality's Political Sign Ordinance Enforceable?
Every campaign season, municipal officials ask us how they can regulate political signs. Municipalities cannot restrict political signs just because they are political signs, even when the restriction's primary aim is to promote aesthetics or to prevent traffic problems. However, municipalities can adopt carefully-worded sign code provisions regulating signs which will survive a challenge if the regulations are reasonable and without censorial purpose. A municipality can restrict political signs if it balances the First Amendment's free speech guarantees, which allow the public to express political opinions on signs or posters, and the municipality's legitimate governmental interests, such as preventing traffic obstructions. Some municipalities include their sign code pro- visions in their zoning ordinances. Other communities use free standing ordinances which can be amended or varied without a noticed public hearing.

The success of a municipality's efforts to regulate political signs will hinge on whether its ordinance is "content-based" or "content-neutral." If a sign ordinance distinguishes between signs on the basis of the political ideas or views expressed on them (for example, if it specifies political signs cannot be placed in public parkways, but real estate signs can), the ordinance is considered "content-based." Content-based sign restrictions will be considered invalid, regardless of whether the restriction involves public or private property, unless the restriction is "necessary to serve a compelling state interest." Some municipalities have attempted to mask content-based restrictions on political signs by claiming the restrictions were necessary to prevent traffic problems, control visual clutter, and preserve aesthetics, when they actually had no proof of such claims. Courts have rejected such arguments, holding that traffic safety and visual aesthetics are not the type of compelling state interests that justify content-based restrictions on expression.

On the other hand, if an ordinance imposes the same regulations on all signs, regardless of content (for example, if it specifies no signs larger than 3' x 4' are allowed, no matter what they say), it will be considered "content-neutral." If an ordinance contains a narrow restriction which serves a significant governmental interest, while leaving open ample alternative channels of communication, the restriction will likely be upheld.

Mere administrative convenience does not suffice as a significant governmental interest. However, preventing visual clutter, preserving aesthetic objectives and preventing traffic problems are sufficient justifications for content-neutral restrictions.

In Taxpayers For Vincent, the Supreme Court upheld a city's total ban on the posting of all signs on public property, finding the complete ban on all signs was a content-neutral regulation, the prevention of "visual blight" was a significant governmental interest, and alternative channels of communication were available, such as handbills. Illinois courts have also adopted this reasoning. For example, the City of Waterloo enacted a zoning ordinance prohibiting display of all temporary signs, such as election signs, for more than 90 days. The City claimed the purpose of the ordinance was "purely a matter of aesthetics, controlling the appearance of the city by requiring temporary signs to be removed after 90 days, regardless of their content or message." The court found that, because the zoning ordinance was applied equally to all signs, the ordinance was content-neutral, the city's aesthetic concerns were valid and adequate alternative channels of communication were available, such as handbills, radio, newspaper, bumper stickers and window signs. Reasonable limitations on the size and height of political signs may also be valid if all signs are similarly restricted. However, communities must be extremely cautious when attempting to totally ban the placement of reasonably-sized signs expressing a political or social message on the owner's private property. For the cases supporting the legal principles presented in this article, please visit the expanded version of this article.

Examples of Sign Ordinance Which Have Been Held Unconstitutional
Various federal and state courts have held the following ordinances, justified by safety or aesthetic concerns, contain unconstitutional restrictions on political expression:

• An ordinance limiting the time political signs may remain posted on commercial or residential property without similar limitations on non-political signs.
• An ordinance banning all signs in residential districts, except "for sale" or "garage sale" signs.
• An ordinance prohibiting all signs except those that are smaller than one square foot; "for sale" or "for lease" signs; church, school or religious signs; commercial signs in commercially zoned or industrially zoned districts; and on-site "gasoline filling station" signs.
• An ordinance limiting the number of temporary signs that could be posted on residential property, but not limiting the number of other signs.
• An ordinance prohibiting the external illumination of political signs on commercial or residential property, but not prohibiting the external illumination of non-political signs.
• An ordinance holding a candidate, on whose behalf a political sign is displayed, responsible for the placement, erection, and removal of those signs.
• An ordinance prohibiting placement of signs on town property without the town board's written consent.

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Is Your Zoning Board Afraid of Variances?
Many zoning boards or city councils are reluctant to grant variances except in the most pressing circumstances, when the variance is overwhelmingly justified. If local officials deny requests for variances because they are afraid to exceed their authority, their fears are unfounded. First, it is unlikely that their ordinance limits their power to grant variances. Second, zoning officials have significant discretion when it comes to making local zoning calls, which the courts will uphold, even in close cases.

This principle was reiterated in Weinstein v. Zoning Board of Appeals of the City of Highland Park, 312 Ill.App.3d 460 (2d Dist. 2000). The homeowners requested a side yard setback variance to build an addition to their existing home. To qualify for a variance, Section 11-31-4 of the Municipal Code requires petitioners to demonstrate that the strict application of zoning requirements would cause them "practical difficulty or particular hardship." Highland Park's zoning ordinance required the petitioners to show "unique circumstances" and a "demonstrable and unusual hardship." At the zoning board hearing, several witnesses, including an architect, a land-use planner, a real estate broker and the homeowner testified that the property was functionally obsolete without the addition and that the proposed addition was the best configuration for the lot, which was small and located on a steep slope. The neighbors presented contrary evidence proposing an alternate configuration which would not require a setback and indicating their property values would be adversely affected by the variance. Ultimately, the zoning board granted the variance, making limited findings.

The neighbors sued, arguing that a) the homeowners failed to prove they had a particular hardship because they could have configured the addition differently and b) the zoning board did not make specific findings. The circuit court upheld the zoning board's decision, as did the appellate court. In doing so, the appellate court noted the homeowners presented evidence showing that, because of the unique circumstances of their property, the strict enforcement of the zoning ordinances would place them under particular hardships. Because these findings were apparent from the record, the court discredited neighbors' arguments about technical wording of the board's order.

This opinion demonstrates that a reviewing court's role is not to re-weigh evidence or to "second guess" a zoning board, but instead to make sure the board followed the proper procedures. A board's decision will be given great weight and will usually be upheld if the record contains evidence to support the board's findings. This case also serves as a reminder of how important it is to make a record of zoning board proceedings. While many municipalities, such as Highland Park, have given their zoning boards the ability to make final decisions on variance requests, other municipalities have their City Council or Village Board make those decisions, relying on recommendations from the zoning board. As a result, the zoning board's findings are often the basis for the final determination. If the zoning board makes the final determination, a court reporter should attend the hearing to preserve a complete written record for a potential circuit court review. For more information, contact Stewart Diamond or Parker Johnson at 312-782-7606.

ATTENTION ALL CANDIDATES:It's time to circulate petitions again! Here are some dates you need to know about:

Candidates seeking election at the Consolidated Election, April 3, 2001:

October 25, 2000 - First day to circulate petitions
January 15-23, 2001 - Petition filing period for candidates

Candidates seeking nomination in the Consolidated Primary, February 27, 2001:

September 19, 2000 - First day to circulate petitions
December 11-18, 2000 - Petition filing period for candidates

If you have any questions regarding petitions, nomination papers or the approaching elections, or if you would like us to review your petitions prior to filing, please call Keri-Lyn Krafthefer at 312-782-7606.

It's Caucus Time!
In municipalities with under 5,000 population, established political parties hold their caucuses on January 8, 2001, and file their certificates of nomination with the municipal clerk during the January 15-23, 2001 filing period. Such municipalities may determine by ordinance by November 15, 2000 that established political parties shall nominate candidates for municipal offices by primary election.

Townships hold their caucuses on January 9, 2001.

Multi-township caucuses will be conducted on January 10, 2001.

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Can Your Park District Benefit from a Corporate Sponsorship?
While the tax cap has limited the revenue available to park districts, residents have pressed for bigger, better, and more imaginative types of recreational facilities. They do not just want a pool - they want aquatic centers with water slides, lazy rivers, sand volleyball and all the latest new options. They want other "state-of-the art" programs and facilities, but not at their expense. What, then, can park districts do to meet these increasing demands? One innovative solution is to find corporate sponsors, which the park district would allow to be the exclusive provider of some service or commodity. (For example, Starbucks could be the only coffee product sold at park district facilities and events.) In exchange, the sponsor pays the park district a fairly substantial fee. Sponsorships have proved successful for college football bowl games (e.g. the Tostitos Fiesta Bowl) and athletic stadiums (e.g. San Francisco's ThreeCom Park and Chicago's United Center); they can be equally effective on a smaller scale.

One disadvantage to a corporate sponsorship is the visual and psychological impact the infiltration of corporate America may have on park districts. A park district's seasonal brochure, which previously had only included descriptions of programs and policies, may now also have advertisements and subtle encouragement to use a particular product or service. Corporate logos could begin appearing on park district facilities and equipment. Park district purists, both on the board and in the community, may be hesitant to embrace this type of partnership.

Currently, because so few suppliers are interested in corporate sponsorships and the terms and conditions are generally unique to the circumstances of the park district and sponsor, such agreements fall within the "high degree of professional skill" exception to park district bidding requirements. In the future, there may be so much competition for corporate sponsorship that park districts may want to "bid out" these arrangements. Think of the funding opportunities if park districts can get a bidding war going between Pepsi and Coca Cola, or between Visa, MasterCard, Discover Card and American Express!

Any sponsorship should be legitimized in a formal agreement, which should consider the following:
1. Spell out the specific understanding of the services or commodities that will be supplied. The supplier will want as expansive an "exclusive" as is possible. Park districts should try to keep the definition limited, because other sponsors may be available for alternate services or commodities.

2. The term of the agreement should be long enough to make it worthwhile for the corporate sponsor and to generate substantial revenue for the district. However, the park district should reserve the right to terminate the agreement, at least on its annual anniversary.

3. The corporate sponsor will want to use the park district's name in advertising outside the park district. The district should restrict the use of its name or logo in outside advertising. At a minimum, the park district should be allowed the right to require written approval before its name or logo can be used in conjunction with the sponsor's advertising materials.

4. The park district should reserve the right to approve the manner, means and location of corporate advertising at its facilities.

5. The park district should not be required to pay for any of the advertising or display of promotional materials by the corporate sponsor. Any such display must comply with all rules, ordinances and regulations of the park district and any local municipality.

6. Where the exclusive sponsorship is for a commodity, the park district must insure the commodity is supplied in a first-class, convenient, cooperative and accessible manner. Dispensing machines must be always operable and serve solely as a convenience to park district residents. The sponsor must fix any problems immediately to the district's satisfaction.

7. The park district should ensure the supplier does not discriminate against any employee or applicant for any illegal reason.

8. The parties should understand and agree that the sponsor is an independent contractor. For more information regarding corporate sponsorship of park districts, contact Rob Bush at (312) 782-7606.

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Student Invocation at School Football Game is Unconstitutional
Most school administrators did not realize that, in pursuing careers in education, they would frequently be presented with constitutional questions. Many constitutional issues arise out of activities on school grounds and in classrooms, ranging from a student's expression through his or her clothing, hair or accessories, to a teacher's speech in the classroom. In June, the United States Supreme Court examined whether a school district's practice in allowing student-led, student-initiated prayer before football games violated the Establishment Clause of the First Amendment to the United States Constitution, which provides, in part, that "Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof."

In Santa Fe Independent Sch. Dist. v. Doe, 120 S.Ct.2266 (2000), the school district had a policy, approved by a majority of the district's students, that permitted a student, who was selected by an election of the student body, to deliver a prayer at varsity football games. Certain students and their parents challenged the policy as being unconstitutional. The school district argued that it was not coercing anyone to support or participate in a religion because the speech at issue was a student's private speech. The Court disagreed, finding that the delivery of the pre-game invocations on government property at government-sponsored, school-related events could not be regarded as "private speech," because the audience could perceive the message as public expression of majority views delivered with the approval of the school district. The Court also found that the school district's policy of permitting these prayers was impermissibly coercive, even though attendance at football games was purely voluntary. The court explained that "[e]ven if we regard every high school student's decision to attend a home football game as purely voluntary, . . . a pre-game prayer has the improper effect of coercing those present to participate in an act of religious worship." The Court recognized that the Constitution does not prohibit any public school student from voluntarily praying at any time.

School's Anti-Disruption Policy Upheld
The Board of Education of Cerro Gordo Community Unit School District No. 100, in Piatt County, Illinois, banned Tamara Nuding from attending all school events and extracurricular activities for a year based on her behavior at a previous school board meeting, where she voiced opposition to the Board's recently-adopted dress code for students, which was adopted to aid student safety. At the meeting, Nuding asked if her attire was appropriate under the district's policy. After the board informed her that it was, she removed a toy gun from her blouse and a pocket knife from her pocket. People present at the meeting were alarmed because they did not immediately learn that the gun was a toy. After the meeting, the school's superintendent filed a complaint against Nuding with the school board, claiming she violated a school policy which prohibited disruption of school-sponsored or related activities. The board acted on the complaint and banned Nuding from school events. In response, Nuding filed a lawsuit alleging that her Constitutional rights were violated, arguing that her "demonstration" was merely an expression of her First Amendment right to free speech that the school's policy could not limit.

Both the trial court and the first district appellate court disagreed, finding the district's policy was legal and did not violate Nuding's rights. The appellate court noted that schools could impose reasonable restrictions on the time, place, and manner of speech occurring in a public forum. The school's policy was content neutral, because it applied to any person who was attending a school-sponsored function, regardless of the person's ideas or views. It was also limited narrowly to restrict only those activities which were disruptive. The policy also left open alternative channels of communication, provided school activities were not impeded. Nuding v. Board of Education of Cerro Gordo CUSD 100, 2000 WL 622100 (Ill.App.4 Dist. 2000) (unpublished decision).

ILLINOIS MUNICIPAL LEAGUE CONFERENCE LINE-UP
Stewart Diamond, Rob Bush and Sharon Eiseman will conduct their popular Council Practices & Procedures session. Stewart, Sharon, Keri-Lyn Krafthefer and Derke Price will speak at the municipal clerks' session. Stewart will also moderate the attorneys' session related to the new IICLE Illinois Municipal Law and Practice Handbook. Many other attorneys from our office will also be in attendance. We look forward to seeing you there!

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What You Don't Know Could Cost You Grant Money
If your public entity is building on land that was formerly farm land or vacant prairie, or rehabilitating downtown areas, it could be risking state and federal funding for its projects unless it complies with the Illinois State Agency Historic Resource Preservation Act, 20 ILCS 3420/1, et seq. and the National Historic Preservation Act, 16 U.S.C. 470, et seq. The purpose of both Acts is to identify and protect state and federal historical and archaeological resources. For any projects funded even partially by any state or federal agency, the funding recipient must give notice to the State Historic Preservation Officer who, in Illinois, is the Director of Historic Preservation. The notice must describe the nature and location of the project and must be given prior to any final plan or undertaking. The Director's staff then determines whether further documentation or investigation of any potentially significant historical sites or artifacts is necessary. If no historically significant resource will be adversely impacted, the Director will issue an approval or clearance letter for the project--and its funding--to go forward. If the project will adversely affect a historic resource, then various procedures must be followed before the project funding can go forward. We recommend that public entities involved in any potentially-covered projects have their project architects contact the Illinois Historic Preservation Agency in Springfield during programming and schematic design in order to minimize the risk of losing any funding or to prevent expensive change orders to correct unacceptable undertakings. Please contact Derke Price at 312-782-7606 if you have questions about either of these Acts.

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Terminiating a Municipal Officer?
These Tips Will Help You Avoid a Lawsuit
The recent proliferation of employment laws has given employees much ammunition to sue public entities over employment practices. When defending public entities in employment actions, we examine how the issues in those cases can be of benefit to other public entities. Tom DiCianni recently successfully defended a village with a population of less than 5,000 in a lawsuit filed by its former police chief. The case underscores an important difference between municipal officers and employees.

The plaintiff had held the position of chief for 12 years, having been annually appointed by the Village President and confirmed by the Village Board at the first meeting of each new fiscal year. Police officers under the chief's charge submitted a series of petitions and complaints about the chief's management style and practices to the Village Board. After discussing the complaints in closed session, the Board decided to terminate the chief, but to pay him his salary for the remainder of his one-year term.

The chief sued the Village, seeking several hundred thousand dollars in damages for lost earnings. He claimed the Village illegally removed him from office in violation of Section 3.1-35-10 of the Illinois Municipal Code, which provides that an appointed municipal officer may only be removed from office by the mayor, after written charges and a finding by the mayor that removal is in the best interests of the municipality. The statute requires the mayor to report the reasons for the removal to the corporate authorities at a meeting held five to ten days after the removal. The corporate authorities can then override the decision with a two-thirds vote, following which the officer must be restored to office.

The court held that when a municipality appoints a person to a municipal office, the removal provisions of 3.1-35-10 must be followed as terms of an “implied contract” between the officer and the municipality. However, the Village ultimately won after the close of the chief's case because the judge found that the chief had an express oral contract to serve as police chief for one year, which had been renewed twelve times. The court found that, even if the chief was an officer, the express contract overrode any “implied” contract incorporating the terms of 3.1-35-10 of the Municipal Code. Since the Village had paid the chief for the remainder of his contract, there was no breach of the contract.

This case was unique because the removal of a police chief is usually governed by the Municipal Code provisions related to Boards of Fire and Police Commissioners in municipalities with populations in excess of 5,000 (or in smaller municipalities which have adopted that process), which usually require appointment and removal by the joint action of a mayor and the council or board.

However, it contains valuable lessons for any municipality employing people who can be considered appointed officers under the Municipal Code, including appointed treasurers, collectors, comptrollers, marshals (which has been interpreted to mean police chiefs), attorneys or corporation counsel, purchasing agents and deputies, auxiliary police officers, police matrons, commissioners of public works, budget directors or budget officer and “other officers necessary to carry into effect the powers conferred upon municipalities.” A municipality should carefully specify those persons it intends to make municipal officers, distinguishing them from non-officers who work solely as employees, independent contractors, or even volunteers. If the municipality intends for a person to hold an office, it should make sure the office-holder follows all of the technical provisions of the Municipal Code's requirements (e.g. taking an oath, posting a bond). If the procedures are followed, the person can be removed like other municipal officers under the provisions of Section 3.1-35-10 of the Code. For further information about these issues, please contact Tom DiCianni or Stewart Diamond.

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Firm News
Victories
Every case we win can ultimately help other public entities and officials who face similar issues. We are proud of the attorneys at our office who have recently prevailed in cases by defending the interests of local governmental and local governmental officials. The firm congratulates Tom DiCianni on his recent series of trial and appellate court victories in the following cases. Rossi v. Village of Huntley was a breach of contract case. The judge entered a directed verdict in favor of the Village at the close of the plaintiff's case during the jury trial. In Vela v. Village of Sauk Village, the plaintiff, a police officer, alleged sexual harassment and discrimination. The Seventh Circuit affirmed the trial court's grant of summary judgment for the Village. The plaintiff in Treece v. City of Naperville had been arrested for intimidating a police officer, following which he filed this suit alleging a civil rights claim for malicious prosecution. The appellate court affirmed the jury's verdict in favor of the City of Naperville. Tom was co-counsel with Howard Levine of the City of Naperville at the trial and during the appeal. In Teverbaugh v. School District 148, the appellate court ruled in the school district's favor, holding that a student who was sexually molested by other students in a junior high school hallway could not sue the school district under a provision of the Illinois constitution which prohibits sexual discrimination in schools. Tom (and David Lincoln Ader) won summary judgment in Fojtik v. Village of Spring Grove, a case in which the plaintiff builder claimed that the Village wrongfully denied him the ability to build within the Village. In Murphy v. Village of Hoffman Estates, the federal appellate court affirmed the motion for summary judgment that Tom (and Keri-Lyn Krafthefer) received for the Village, which dismissed an 18-count complaint of a former employee who alleged the Village discriminated against him under the Americans with Disabilities Act because of his status as a recovered alcoholic. David Lincoln Ader and Rob Bush also received a favorable ruling from the Seventh Circuit appellate court in Harper v. Chicago Heights. The court's order upheld the Chicago Heights Park District's election system as satisfying the Voting Rights Act.

New Clients
We are happy to report that we have been hired to represent the Batavia Park District and the Clarendon Hills Park District. We are also handling specialty water rate work for the Cities of O'Fallon and Fairview Heights and the Village of Caseyville, and other specialty work for the Village of Manteno and the Village of Shiloh. The firm is opening an office in Crystal Lake to better serve our clients in McHenry County and beyond.

Congratulations!The firm congratulates Tom DiCianni, who was elected to serve as the Chair of the Chicago Bar Association's Federal Civil Practice Committee, and Darcy Proctor, who is completing her second year on the Board of the Women's Bar Association of Illinois. Darcy was also appointed to serve as the Co-Chair of the WBAI's Public Office Committee and to the Illinois State Bar Association's Tort Section Council. We also extend our best wishes to our law clerk, Scott Spears, who married Gina D'Antonio on August 5th. Gina is a teacher with the Chicago Public Schools. Scott and Gina honeymooned in Italy.

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'Round 'Round, Get Around, We Get Around
Ancel, Glink, Diamond, Bush, DiCianni & Krafthefer, P.C. is proud to continue the firm's tradition of keeping local governmental officials and other attorneys informed about recent changes in the law by speaking at seminars and publishing articles. Some of the most recent contributions of time and effort our attorneys have made towards the accomplishment of this goal include the following:

Speeches
Bob Rolek spoke on Legislative Issues and Grants at the IAPD conference. He also addressed the Illinois Parks and Recreational Associations' University Series in May. Bob also chaired the Local Governmental Seminar of the Lake County Bar Association and moderated an all day session on current governmental issues. Tom DiCianni will moderate the CBA's November seminar on Federal Expert Witness Practice. Darcy Proctor will be speaking on discovery and federal expert witnesses at the seminar. Tim Guare spoke on public employment issues at a public personnel law seminar conducted by the Council of Education and Management and at the IML's municipal attorneys' session in February. He also provided guidance on drug testing procedures and related issues at the Illinois Public Employer Labor Relations Association's workshop session, and will be speaking at the annual IPELRA conference in Galena this October. Tim is also a member of a panel which will discuss the ADA, FMLA and workers compensation at the Public Employer Labor Relations Law Program at Chicago-Kent College of Law. In November, Tim and Bill Kling will be presenters at the Illinois Council of Community College Administrators' annual Fall Conference in Springfield. Bill is also scheduled to lead a workshop on legislative advocacy for the Illinois chapter of the National Association of Telecommunications Officers and Advisors (NATOA). Rob Bush spoke on inclusion under the ADA at the International Association of School Business Officials conference in Minneapolis. Sharon Eiseman conducted Sexual Harassment Prevention Training for Supervisors of the City of Peoria. In October, Sharon and Keri-Lyn Krafthefer will be speaking at the Municipal Clerks Institute Academy in Springfield.

Publications
Darcy Proctor has completed the 2000 Edition of our office's Illinois Governmental Tort Immunity Handbook. This edition includes a new chapter discussing immunity for medical, hospital and public health activities. Tom DiCianni and Stewart Diamond's article, "Irrational Government," analyzes the new equal protection theory the Supreme Court approved in Village of Willowbrook v. Olech. The article appears in the October edition of the DRI's For The Defense journal. Tom was the editor of the Governmental Liability section of the publication. Bill Kling's article, "Coming Together to Address Student Aggression and School Safety" was the lead article in the Spring 2000 issue of the Public Employee Relations Reporter of Illinois, jointly published by the University of Illinois and IIT-Chicago Kent College of Law.

New Muncipal Law and Practice IICLE Handbook
Many of our attorneys authored or co-authored chapters of the updated 2000 IICLE Municipal Law and Practice in Illinois handbook. Stewart Diamond was the original General Editor for the publication over 25 year ago, and still serves in that role. Our firm's updated chapters include Procedures and Practices (Stewart Diamond and Sharon Eiseman), Municipal Labor Law (Stewart, Tim Guare, Keri-Lyn Krafthefer and Dina Kapernekas), Annexation and Annexation Agreements (Stewart, Bob Rolek and Bill Kling), and Tax Increment Financing (Sharon Eiseman). New chapters include Construction Contracts (Derke Price), Adult Uses (Dean Krone and Todd Osbron), Tort Immunity (Stewart, Tom DiCianni and Darcy Proctor) and Municipal Elections (Keri-Lyn Krafthefer). Because of the firm's extensive participation in the comprehensive IICLE update this year, the firm will update the IML's Illinois Municipal Handbook in 2001.

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Contributors: Lucy Bednarek Fadel, Rob Bush, Stewart Diamond, Tom DiCianni, Parker Johnson, Dina Kapernekas, Derke Price
Editor: Keri-lyn Krafthefer; Layout and Design: Julie Stenkraus