Bio-Medical Laboratories, Inc. v. Trainor
68 Ill. 2d 540 · Illinois Supreme Court · 1977-10-17
Holding
A suit to enjoin a state officer from acting in excess of delegated authority is not a claim against the State and may proceed in circuit court; it does not fall within the Court of Claims' exclusive jurisdiction.
Context
Medicaid provider sued to stop the Public Aid Director from suspending its participation. The court held plaintiff sought no present money claim against the State but to restrain ultra vires action, so sovereign immunity did not bar circuit-court jurisdiction and the Court of Claims was not the exclusive forum. Foundation of the officer-suit exception.
officer-suit exceptionsovereign immunityprospective relief
Full opinion text (public domain): https://openjurist.org/68/ill2d/540/bio-medical-laboratories-inc-v-trainor