IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOISCOUNTY DEPARTMENT – CHANCERY DIVISION
The REGIONAL TRANSPORTATION AUTHORITY, )an Illinois special purpose unit of government )and municipal corporation, ))Plaintiff, ))vs. ) No.)UNITED AVIATION FUELS CORPORATION, )UNITED AIRLINES, INC., and THE CITY )of SYCAMORE, an Illinois home rule )municipality, ))Defendants. )
COMPLAINT FOR DECLARATORY JUDGMENT AND INJUNCTIVE RELIEF
NOW COMES the REGIONAL TRANSPORTATION AUTHORITY, an Illinois special purposeunit of government and municipal corporation (“RTA” or “Plaintiff”), and for its causes of actionagainst Defendants UNITED AVIATION FUELS CORPORATION (“United Fuels”), UNITED AIRLINES,INC. (“United Airlines”), and the City of Sycamore (“Sycamore”), states as follows:
1. This case is filed to redress the improper tax siting by Defendants of retail saletaxes on enormous sales of jet fuel. This practice, which has been ongoing since approximately2001, has diverted tax monies from Plaintiff and other municipalities to Defendants.2. Plaintiff seeks a declaratory judgment finding this practice improper, equitablerelief enjoining this practice, a declaration that the Defendants’ various agreements allowing thispractice are void, a constructive trust upon any monies held by Defendants which were obtainedfrom this practice, and for the recovery of appropriate damages.