Illinois Supreme Court Abolishes Long-Standing Public Duty Rule

by Holland & Knight LLP
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HIGHLIGHTS:

  • A divided Illinois Supreme Court has abolished the common-law standard that a local governmental body and its employees, when providing services like police and fire services, do not owe a duty of care to individual members of the public but instead owe a duty only to the public generally.
  • The decision leaves a gap in protection of public employees against claims of willful and wanton conduct.
  • The Illinois Legislature can act to reinstate the public duty rule.

A divided Illinois Supreme Court issued its decision in Coleman v. East Joliet Fire Protection District et al., 2016 IL 117952, on Jan. 22, 2016, abolishing the common-law standard that a local governmental body and its employees, when providing services like police and fire services, do not owe a duty of care to individual members of the public but instead owe a duty only to the public generally. This standard, widely known as the "public duty rule," was conceived by the U.S. Supreme Court more than 150 years ago and has been firmly in place in Illinois for more than 50 years.

The public duty rule, which prevents individual citizens from suing public employees under most circumstances, largely overlaps the Illinois Local Governmental and Governmental Employees Tort Immunity Act, 745 ILCS 10/1-101 et seq., and several other Illinois laws that include immunity provisions. But, unlike the public duty rule, those laws do not protect public employees against claims of willful and wanton conduct. The abolition of the public duty rule thus creates a gap of sorts – leaving public employees subject to claims of willful and wanton conduct.

The lead opinion of the Coleman Court, joined only by its author Justice Thomas Kilbride and Justice Anne Burke, determined that the public duty rule should be abolished because (1) the rule has been "muddled" by inconsistent court rulings, (2) the rule is incompatible with Illinois immunity laws that carve out willful and wanton conduct, and (3) the rule is obsolete in light of those statutory immunities.

Two justices specially concurred with the lead decision, agreeing that the public duty rule should be abolished but for reasons entirely different from the reasons stated in the lead opinion. The concurring opinion was written by Justice Charles Freeman and joined by Justice Mary Jane Theis.

The three remaining justices dissented in a strongly worded opinion written by Justice Robert Thomas and joined by Chief Justice Rita Garman and Justice Lloyd Karmeier.

Immediate Impacts

The Coleman decision likely will increase the number and duration of lawsuits filed against public employees, despite the immunity provisions of the Tort Immunity Act. In addition, public employees now are at risk of liability for willful and wanton conduct, unless the Illinois Legislature acts to fill that gap. Additionally, public employees rightly rely on consistency in the court’s decisions on critical issues such as immunity and liabilities. The court’s willingness here to abandon a long-held precedent adds unfortunate uncertainty to these and other matters important to local governments. The impacts of Coleman are discussed further below.

Difficult Facts

The Coleman case arose out of very unfortunate facts: In June 2008, Coretta Coleman called 911 from her home in Will County and told the operator she could not breathe and needed an ambulance. The operator transferred the call to a dispatcher, but did not wait for the dispatcher to answer before hanging up. The dispatcher took the call and tried to ask questions of the caller, but Coleman did not answer. The dispatcher hung up and redialed Coleman's number twice, but got a busy signal each time. The dispatcher placed Coleman's call in line for an ambulance response, as an "unknown medical emergency." (At the time of Coleman's call, Will County was experiencing a major outbreak of tornadoes that caused injuries and widespread property damage.)

A few minutes later, an ambulance was dispatched to the Coleman residence. The crew rang the doorbell and pounded on the door, but got no response. The crew called a supervisor who ordered them to leave the residence and go back into service. The crew departed approximately 5 minutes after it arrived.

Shortly thereafter, Coleman's neighbor, who had spoken to the ambulance crew, called 911 and reported an emergency at "1600 Sugar Creek Drive." The neighbor talked to the same operator who had answered the call from Coleman. The operator called the same dispatcher as before, and this time talked to the dispatcher about the call and gave the dispatcher the address "1600 Sugar Creek." The dispatcher sent an ambulance to "1600 Sugar Creek Court" instead of 1600 Sugar Creek Drive (in the same subdivision). When the ambulance crew discovered there was no 1600 Sugar Creek Court, the crew called the dispatcher for an address check.

While the dispatcher was attempting to secure the correct address, the ambulance crew found 1600 Sugar Creek Drive – 41 minutes after Coleman's initial call. The crew knocked on the door but received no answer. Coleman's husband then arrived home and let the crew into the house. The crew found Coleman unresponsive, and, after transporting her to the hospital, she was pronounced dead of cardiac arrest.

Trial and Appellate Court Decisions

In the lawsuit brought on behalf of Coleman's estate, the defendants filed motions to dismiss all counts of the complaint, claiming immunity under the Emergency Medical Services Systems Act, 210 ILCS 50/3.150, and the Emergency Telephone System Act, 50 ILCS 750/15.1. The plaintiff did not the contest the motions as they related to counts alleging negligence by the defendants, and the court dismissed those counts. The court denied the motions related to counts alleging willful and wanton conduct.

The defendants later filed motions for summary judgment on the willful and wanton conduct counts, arguing both that they had no duty under the public duty rule and that they had immunity under the two laws noted above. The court granted those motions, applying the public duty rule. The court did not examine the issues of statutory immunity.

The appellate court affirmed the rulings of the trial court.

Illinois History Regarding Immunity and Public Duty Rule

In the Court's lead opinion, Justice Kilbride writes that the primary issue before the Court is whether the public duty rule remains viable. He begins his analysis by examining at great length the history of governmental immunity in Illinois. He concludes by noting that the Court effectively abolished common-law immunity in the well-known case titled Molitor v. Kaneland Community Unit District No. 302, 18 Ill. 2d 11 (1959). And he notes that the Illinois Legislature responded to Molitor by enacting the Tort Immunity Act and other immunity provisions such as the two laws noted above.

Justice Kilbride then reviews the history of the public duty rule in Illinois. He discusses at length the distinction between sovereign immunity, which exists regardless of the existence of any duty, and the public duty rule, which "is not rooted in sovereign immunity . . . "[but] developed independently and separately from concepts of governmental immunity." 2016 IL 117952, p. 14. The issue of duty, he writes, "is a separate and distinct issue from whether a defense of governmental immunity applies." Id. He concludes "the time has come to abandon the public duty rule ...." Id. at p. 17.

Stare decisis vs. Obsolescence

The lead opinion briefly addresses the issue of stare decisis, the policy of courts to honor precedents set in their previous decisions and not disturb settled points. Justice Kilbride quotes at length from the Court's decision in People v. Sharpe, 216 Ill. 2d 481 (2005), which strongly affirms the importance of stare decisis. He nevertheless concludes that a departure from stare decisis is warranted in Coleman because:

(1) the jurisprudence has been muddled and inconsistent in the recognition and application of the public duty rule and its special duty exception; (2) application of the public duty rule is incompatible with the legislature's grant of limited immunity in cases of willful and wanton misconduct; and (3) determination of public policy is primarily a legislative function and the legislature's enactment of statutory immunities has rendered the public duty rule obsolete. Id. at p. 18.

He concludes by stating "the underlying purposes of the public duty rule are better served by application of conventional tort principles and the immunity protection afforded by statutes than by a rule that precludes a finding of a duty on the basis of the defendant's status as a public entity." Id. at p. 20.

Special Concurrence

In an opinion specially concurring with the lead opinion, Justice Freeman disagrees with the lead opinion's distinction between sovereign immunity and the public duty rule. Rather, he writes, they are "predicated on exactly the same concern – the notion that when a municipality performs a governmental function, the service is provided to protect the general welfare of the public. ... [T]he public duty rule has always been predicated on the very same basis as the concepts underlying local governmental immunity" Id. at p. 22.

The public duty rule can be abolished, Justice Freeman concludes, not for the conflict between immunity and the rule, but rather because "the passage of various statutes providing for certain immunities with regard to official conduct of local governmental entities constitutes a comprehensive scheme for balancing the private and public interests at stake in assessing municipal tort liability." Id. at 23.

Dissent

In a bluntly worded dissenting opinion, Justice Thomas takes the lead opinion to task on the issue of stare decisis. He writes that the three reasons given by Justice Kilbride for the departure are "not compelling, not in the least." Id. at p. 26.

The first reason – expressing concern about "muddled and inconsistent opinions" – is simply incorrect, he writes. Id. at pp. 26-27. The court decisions are clear enough on the application of the public duty rule.

The second reason – that the public duty rule is inconsistent with the statutory immunity carve-out for willful and wanton conduct – is insufficient first because this circumstance has existed for decades and there are no new facts or circumstances that demand change, and second because immunity is fundamentally different in theory and application from a common-law duty and thus there is no inconsistency. Id. at pp. 28-29.

The third reason – that the Illinois Legislature has enacted statutory immunities that render the public duty rule obsolete – is contrary to the Court's consistent holding that the public duty rule has survived the passage of the Tort Immunity Act. Justice Thomas writes that the survival of the public duty rule is based on the distinction between the issue of whether a duty is owed and the issue of whether there is governmental immunity. Under sovereign immunity, a governmental body is immune from tort liability regardless of any apparent duty. In contrast, under the public duty rule, the tort liability never existed precisely because no duty existed other than to the general public. Id. at pp. 29-30.

Justice Thomas disagrees with the concurring opinion for two principle reasons: Justice Freeman ignores the issue of stare decisis and concludes that there is no meaningful distinction between sovereign immunity and the public duty rule, a position Justice Thomas rejects as noted above.

The Lasting Impact

Many personal injury complaints are brought against public employees despite the public duty doctrine, and many of those complaints include allegations not only of negligence but also of willful and wanton conduct. The abolition of the public duty doctrine seems nearly certain to result in a significant increase in claims of willful and wanton conduct, however far-fetched they may be. As a result, fewer lawsuits will be resolved by motions to dismiss, lawsuits will be more expensive to defend when discovery is required to support motions for summary judgment, and public employees are not protected against liability for willful and wanton conduct. These are serious matters.

On the other hand, concern that public employees are now at immense risk of liability may be overstated. A claim of willful and wanton conduct demands proof of very bad conduct. "Willful and wanton" often is defined as requiring conduct that was intentional, exhibits reckless disregard for the safety of others, and includes actions taken in conscious disregard of or reckless indifference to the consequences of the actions. Most public employees do not engage in willful and wanton conduct. For example, it would be very surprising if, on remand, the trial court in the Coleman case rules that the defendants acted willfully and wantonly.

In any case, the Illinois Legislature has the power to close the liability gap created by the abolition of the public duty rule. The Legislature may codify the rule or amend immunity laws to extend to willful and wanton conduct under certain circumstances. If the Legislature takes this issue up, it will be interesting to hear the debate. There certainly will be strong support for a legislative response to the Coleman decision. There may also be voices for the position that the Tort Immunity Act is sufficient in its current form.

Was the Tort Immunity Act's carve-out of willful and wanton conduct drafted that way because legislators knew the public duty rule covered that conduct? We may find out.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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