Illinois Appellate Court: Wolinski v. Chicago Police Board Decision

The Illinois Appellate Court, First District, Second Division, issued an order on September 8, 2026, in the case of *Wolinski v. Police Board of the City of Chicago*, cited as 2026 IL App (1st) 242353-U.

This development is particularly significant for Illinois practitioners due to the explicit notice that the order was filed under Supreme Court Rule 23 and "is not precedent except in the limited circumstances allowed under Rule 23(e)(1)." This designation means that, generally, the order cannot be cited as binding authority in other cases, which is a critical distinction for legal research and argumentation. The purpose of Rule 23 is to manage the volume of published opinions and ensure that only cases establishing new law or significantly altering existing law are given precedential weight. For attorneys, understanding this limitation is paramount when evaluating the persuasive value of appellate court decisions and advising clients on the likelihood of success in similar matters.

The legal context for this order is the Illinois Appellate Court, which serves as the intermediate appellate court in Illinois, reviewing decisions from the state's circuit courts. The "First District, Second Division" specifies the particular division of the appellate court that heard the matter. Illinois Supreme Court Rule 23 governs the publication and precedential value of appellate court decisions, with Rule 23(e)(1) outlining the narrow exceptions under which an unpublished order may be cited, typically for purposes of res judicata, collateral estoppel, or to establish the law of the case. The "U" in the citation "242353-U" commonly denotes an unpublished or Rule 23 order. The involvement of the "Police Board of the City of Chicago" suggests an administrative law context, likely an appeal from an administrative decision.

Illinois attorneys must be acutely aware of the non-precedential nature of Rule 23 orders. While these orders provide insight into how the appellate court has ruled on specific facts, they generally cannot be used to establish legal principles in unrelated cases. Practitioners should carefully review Rule 23(e)(1) to understand the precise, limited exceptions for citation. When encountering such an order, it is crucial to determine if any of these exceptions apply before attempting to rely on it in court. This also implies that the specific outcome of this case, while important to the parties involved, will not broadly shape Illinois jurisprudence or create new legal standards for other cases. The specific outcome of this order is not reported in the excerpt.