In Policemen’s Benevolent Labor Committee v. City of Sparta, 2020 IL 125508 (November 19, 2020), the City’s “activity points system” required all full-time police officers to meet a monthly points minimum. The system was used to give an award for the most points attained but it was also used as a basis for discipline for low scoring officers. The police union filed a declaratory judgment action seeking a ruling that an activity-points policy used by the City to evaluate the performance of its police officers established an unlawful ticket quota in violation of Section 11-1-12 of Illinois Municipal Code. The plain language of section 11-1-12 of Municipal Code prohibits municipalities from including the issuance of citations in a “points of contact” system used to evaluate the job performance of police officers. By granting awards based on points of contact, the City’s policy impermissibly provided an incentive for officers to write citations to accumulate as many points as possible. As a result, the Supreme Court directed summary judgment for the union.

It should be pointed out that the Court seemed to sympathize with the need to be able to use the issuance of citations (a duty of an officer) as a basis for evaluation.  However, the Court punted that problem back to Springfield:  

We recognize the argument by amicus that a fair points policy must account for the full range of officer activity and that the failure to include the issuance of citations as part of duty performance undercuts important traffic safety enforcement programs. While those arguments raise important considerations, we are bound by the plain statutory language and may not alter it based on our views of proper public policy. The arguments of the City and amicus, seeking to include the issuance of citations in points-of-contact systems, are more properly addressed to the – 8 – legislature. The statute, as it is currently written, expressly prohibits that practice, and the statute must be enforced as written.

It remains to be seen if the Illinois legislature takes up this issue by amending the statute. In the meantime, municipalities should look carefully at their discipline policies and collective bargaining agreements.

For more information about this article, contact Tressler attorney John O’Driscoll at