No. 108184 IN THE SUPREME COURT OF ILLINOIS GEORGE H. RYAN, SR., Plaintiff-Appellee, v.

THE BOARD OF TRUSTEES OF THE GENERAL ASSEMBLY RETIREMENT SYSTEM OF ILLINOIS, REP. KURT M. GRANBERG, SEN. JAMES CLAYBORNE, SEN. DON HARMON, REP. RICHARD T. BRADLEY, SEN. WILLIAM BRADY, REP. LEE DANIELS, and REP. PHILIP COLLINS, in their official capacities, Defendants-Appellants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) On Appeal from the Appellate Court of Illinois, First Judicial District No. 1-07-1601

There on Appeal from the Circuit Court of Cook County, Illinois, County Department, Chancery Division No. 06 CH 28340

The Honorable MARTIN S. AGRAN, Judge Presiding.

BRIEF OF DEFENDANTS-APPELLANTS LISA MADIGAN Attorney General State of Illinois MICHAEL A. SCODRO Solicitor General 100 W. Randolph St., 12th Floor Chicago, Illinois 60601 (312) 814-3312 Attorneys for Defendants-Appellants JAN E. HUGHES Assistant Attorney General 100 W. Randolph St., 12th Floor Chicago, Illinois 60601 (312) 814-2129 ORAL ARGUMENT REQUESTED

NATURE OF THE CASE Section 2-156 of the Illinois Pension Code, which pertains to the General Assembly Retirement System (“the System”), provides that “[n]one of the benefits herein provided for shall be paid to any person who is convicted of any felony relating to or arising out of or in connection with his or her service as a member.” 40 ILCS 5/2-156 (2008). The System’s Board of Trustees applied that provision to terminate all pension benefits of George Ryan, Sr., because his federal convictions for racketeering, mail fraud, making false statements, filing false tax returns, and other offenses were based on his conduct during his service to the State while a member of the System.1 The Board rejected Ryan’s argument that he should only have to forfeit those benefits relating to his service as Secretary of State and Governor, the offices he occupied when he engaged in the criminal conduct. The circuit court upheld the Board’s decision, but the appellate court reversed, holding that the phrase “for the period of service in such office” from the Pension Code’s definition of “member” limited the forfeiture provision to the period of service in the offices directly related to the felony convictions.

The current members of the Board of Trustees are: Sen. James Clayborne (Chairman), Rep. Mark Beaubien, Jr. (Vice Chairman), Sen. Don Harmon, Sen. William Brady, Rep. Kevin A. McCarthy, Rep. Dan Reitz, and former Rep. Philip Collins (retired member). Members Beaubien, McCarthy, and Reitz were appointed after Ryan filed his complaint and are substituted as defendants pursuant to section 2-1008(d) of the Code of Civil Procedure (735 ILCS 5/2-1008(d) (2008)).

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ISSUE PRESENTED FOR REVIEW Whether the Board of Trustees of the General Assembly Retirement System properly terminated all of George Ryan’s retirement benefits because he was convicted of felonies relating to, arising out of, and in connection with his service to the State of Illinois as a member of the System.

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STATUTES INVOLVED Article 2 of the Illinois Pension Code pertains to the General Assembly Retirement System. 40 ILCS 5/2-101 – 5/2-162 (2008). Section 2-105 of the Pension Code defines “member” as: Members of the General Assembly of this State including persons who enter military service while a member of the General Assembly and any person serving as Governor, Lieutenant Governor, Secretary of State, Treasurer, Comptroller, or Attorney General for the period of service in such office. 40 ILCS 5/2-105 (2008) (Appendix (“App.”) at A33). Section 2-156 of the Pension Code provides in relevant part as follows: Felony conviction. None of the benefits herein provided for shall be paid to any person who is convicted of any felony relating to or arising out of or in connection with his or her service as a member. 40 ILCS 5/2-156 (2008) (App. at A34).

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STATEMENT OF FACTS A. Background Ryan, who was born on March 24, 1934, was appointed to fill a vacant seat on the Kankakee County Board of Supervisors in 1966 (Supplemental Record (“S.R.”) C. 49, 283). He was subsequently elected and re-elected to the County Board, serving from 1966 to 1972, including a two-year period as Chairman from 1970 to 1972 (S.R. C. 283). In November 1972, Ryan was elected to the Illinois General Assembly as a representative for the Kankakee area (id.). He was re-elected four times and represented that district until 1982 (id.). The System sent Ryan a letter in January 1973 to acquaint him with the pension plan available to members of the General Assembly (S.R. C. 51). The letter informed him that he would become a participant automatically unless he elected otherwise (id.). Ryan did not opt out and, in fact, requested the Illinois Municipal Retirement Fund (“IMRF”) to transfer the credits he had earned as a county supervisor from that fund to The System (S.R. C. 52). In March of 1973, the IMRF sent the System a check for $996.80, representing Ryan’s contributions, interest, and credits earned from February 1967 through January 1973 (id.). In April of 1973, the System notified Ryan that he owed a balance of $6,608.89 to establish 5.9 years of credit associated with the transfer from IMRF (S.R. C. 54).

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He submitted the payment in May of 1981 (S.R. C. 57). In 1982, Ryan was elected Lieutenant Governor, and James R. Thompson was re-elected Governor (S.R. C. 283). Both Thompson and Ryan won re-election in 1986 (id.). In 1990, Ryan was elected to a four-year term as Secretary of State and was re-elected to a second term in November 1994, serving through early January 1999 (id.). Ryan was elected Governor in November 1998 and served in that position from January 1999 to early January 2003 (S.R. C. 284). On December 20, 2002, Ryan applied for a retirement annuity to begin in January 2003, when his term as Governor ended (S.R. C. 49-50). His yearly salary was $150,691 at the time (S.R. C. 49). Based on his entitlement to the maximum of 85% of his final salary, the System computed his monthly retirement benefit as $10,673.95 (S.R. C. 77-78). A federal grand jury indicted Ryan in December 2003 on felony charges for racketeering, conspiracy, mail fraud, making false statements to the Federal Bureau of Investigation, and income tax violations (S.R. C. 120-210). The indictment alleged that Ryan engaged “in a scheme to defraud the People of the State of Illinois and the State of Illinois of money, property, and the intangible right to the honest services of defendant RYAN, in his capacity as a state official” (S.R. C. 133). The conduct described in the indictment occurred when Ryan was

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Secretary of State and Governor and resulted in, among other things, “hundreds of thousands of dollars in benefits for [co-defendant Lawrence] Warner and Ryan.” United States v. Warner, 498 F.3d 666, 675 (7th Cir. 2007). On April 17, 2006, a jury found Ryan guilty on all counts. Id. at 674. The district court set aside the jury’s verdict with respect to two mail fraud counts, entered judgment against Ryan on the remaining counts, and sentenced him to 78 months in prison. Id.; see generally United States v. Warner, No. 02 CR 506-1, 2006 WL 2583722 (N.D. Ill. Sept. 7, 2006). Ryan appealed to the United States Court of Appeals for the Seventh Circuit, which affirmed the convictions. Warner, 498 F.3d at 678-705. The United States Supreme Court denied certiorari. See 128 S. Ct. 2500 (2008) B. Proceedings Before The System When Ryan was convicted, Timothy Blair, Executive Secretary of the System, sought the opinion of Illinois Attorney General Lisa Madigan regarding whether the felony convictions precluded Ryan from continuing to receive his pension (S.R. C. 211-12). Attorney General Madigan expressed her opinion in accordance with the law that (1) Ryan forfeited all of his pension benefits because his felony convictions arose out of and in connection with his service as Secretary of State and Governor, (2) his pension should cease as of the date of his convictions, and (3) he was entitled to a full refund of his contributions to the

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System, including those associated with the credits transferred from the IMRF (S.R. C. 214-38). The Attorney General concluded that Ryan forfeited all of his pension benefits, not just those that accrued while he served as Secretary of State and Governor, based on section 2-156 of the Pension Code (40 ILCS 5/2-156), which states that “[n]one of the benefits herein provided for shall be paid to any person who is convicted of any felony relating to or arising out of or in connection with his or her service as a member” (S.R. C. 223-31). The Attorney General stated that “the plain language of section 2-156 mandates the forfeiture of all pension benefits provided for by the System where a nexus exists between the felony conviction and the participant’s official duties, regardless of whether the participant held distinct offices or positions with the State” (S.R. C. 224). In the opinion of the Attorney General, the trigger for forfeiture is the existence of a connection between the felony conviction and the participant’s service while a member (id.). The Attorney General also stated that her opinion was consistent with case law interpreting similar pension forfeiture provisions as to whether a partial or total forfeiture was mandated under the particular circumstances (S.R. C. 225-31 (citing Taddeo v. Bd. of Trustees of the Ill. Mun. Ret. Fund, 216 Ill. 2d 590 (2005); Wells v. Bd. of Trustees of the Ill. Mun. Ret. Fund, 361 Ill. App. 3d 716 (2nd Dist. 2005), appeal denied, 217 Ill. 2d 627 (2006);

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Grever v. Bd. of Trustees of the Ill. Mun. Ret. Fund, 353 Ill. App. 3d 263 (2nd Dist. 2004), appeal denied, 217 Ill. 2d 561 (2005))). On September 19, 2006, Executive Secretary Blair informed Ryan that his pension, health, dental, vision, and life insurance benefits would be suspended effective September 6, 2006, the date of sentencing (S.R. C. 249). As a dependent under the group health plan, Ryan’s wife, Lura Lynn, had the option of purchasing COBRA benefits (id.). Blair informed Ryan that he or his representative could present his case at the Board of Trustee’s November 15, 2006 meeting (id.). Ryan submitted a memorandum in support of his claim to the Board (S.R. C. 254-63). He did not dispute that his pension benefits earned as Secretary of State and Governor should have terminated because his felony convictions related to his conduct in those offices; however, he claimed that he was entitled to a pension based on credits earned while he served as a State Representative and Lieutenant Governor because his conduct leading to the felony convictions was unrelated to his service in those positions (S.R. C. 257-62). Ryan also argued that the IMRF credits that he earned for service on the Kankakee County Board were not subject to forfeiture (S.R. C. 262-63).2 Ryan’s counsel reiterated these arguments at the November 15, 2006 Board meeting (S.R. C. 267-68, 293-98). At a special meeting on November 29, 2006, the Board unanimously

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ratified a decision prepared by the System’s staff that terminated all of Ryan’s benefits effective September 6, 2006 (S.R. C. 280-81). In its written decision (S.R. C. 282-92; App. at A21-A31), the Board found that the plain language of the felony forfeiture provision mandated the forfeiture of all of Ryan’s benefits because “the trigger for forfeiture under Section 2-156 is the existence of a connection between the felony conviction and the participant’s service to the State while a member” (S.R. C. 287). The Board reasoned that had the General Assembly intended to limit the application of the forfeiture provision to particular offices or positions held by the participant, it could have written in such a limitation, but it did not (id.). Additionally, the Board agreed with the Attorney General’s analysis of the cases examining whether a felony conviction results in a total forfeiture of pension benefits (Taddeo, Wells, and Grever) and concluded that its decision was consistent with those cases (S.R. C. 287-89). According to the Board, all of Ryan’s pension benefits accrued while he was in the service of one employer – the State of Illinois – and, therefore, his felony convictions mandated the forfeiture of his entire pension (S.R. C. 289). The System notified Ryan that he was entitled to a refund of his contributions totaling $235,508.58 (S.R. C. 303; App. at A32). C. Circuit Court Proceedings Ryan timely filed a complaint for administrative review of the Board’s

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decision (C. 3-10). He later filed a motion for summary judgment, to which the Board responded (C. 78-92, 97-101; S.R. C. 8-23). Following a hearing, the circuit court issued a memorandum opinion on May 31, 2007, affirming the Board’s decision in all respects (C. 103-13; App. at A10-A20; Tr. 5-27). Ryan timely appealed (C. 114-15). D. Appellate Court Opinion The appellate court reversed, holding that Ryan forfeited only that part of his pension related to his service as Governor and Secretary of State. Ryan v. Bd. of Trustees of the Gen. Assembly Ret. Sys., 388 Ill. App. 3d 161 (1st Dist. 2009) (App. at A1-A9). The court relied on the definition of “member” to find that “the felony conviction ‘relating to or arising out of or in connection with his or her service as a member’ must be linked to the ‘the [sic] period of service in such office.’” Ryan, 388 Ill. App. 3d at 168 (App. at A8). The appellate court also concluded that Taddeo and Grever mandated reversal and that Wells was distinguishable because the felony forfeiture provision at issue there uses the phrase “service as an employee,” whereas the felony forfeiture provision applicable to Ryan uses the phrase “service as a member,” which, in the court’s view, “limits the scope to a specific office held.” Ryan, 388 Ill. App. 3d at 167-68 (App. at A7-A8).

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ARGUMENT The Board Of Trustees Correctly Concluded That Ryan Forfeited All Of His Pension Benefits Because His Felony Convictions Related To, Arose Out Of, And Were Connected With His Service To The State While A Member Of The System. A. Introduction and standard of review Section 2-157 of the Illinois Pension Code provides that judicial review of final decisions of the System’s Board of Trustees is governed by the provisions of the Administrative Review Law (ARL). 40 ILCS 5/2-157 (2008). Under the ARL, an agency’s findings and conclusions on questions of fact shall be held by the reviewing court to be prima facie true and correct. 735 ILCS 5/3-110 (2008). This Court reviews the decision of the agency, not the appellate court. Sangamon County Sheriff’s Dep’t v. Ill. Human Rights Comm’n, 233 Ill. 2d 125, No. 105517, 2009 WL 1011986, at *4 (Apr. 16, 2009). The facts are not in dispute; rather, the issue involves the proper interpretation of the Pension Code. As such, the Board’s decision is reviewed de novo because the case presents a question of law. Roselle Police Pension Bd. v. Vill. of Roselle, 232 Ill. 2d 546, 552 (2009); Shields v. Judges’ Ret. Sys., 204 Ill. 2d 488, 491-92 (2003). Under any standard of review, including de novo, a plaintiff in an administrative review proceeding bears the burden of proof, and relief will be denied if he fails to sustain that burden. Wade v. City of N. Chicago Police Pension Bd., 226 Ill. 2d 485, 505 (2007). -11-

Statutory construction requires courts to ascertain and give effect to the intent of the legislature. Wade, 226 Ill. 2d at 509; Shields, 204 Ill. 2d at 493. The plain language of the statute is the most reliable indicator of that intent. Roselle, 232 Ill. 2d at 552. If an ambiguity exists, extrinsic aids, such as legislative history, may be examined. County of DuPage v. Ill. Labor Relations Bd., 231 Ill. 2d 593, 604 (2008). Despite the de novo review applicable to statutory construction, substantial weight and deference are given to an agency’s interpretation of a statute that it is charged with administering. Roselle, 232 Ill. 2d at 559; Abrahamson v. Ill. Dep’t of Prof’l Regulation, 153 Ill. 2d 76, 98 (1992). That interpretation is based on the agency’s experience and expertise and, therefore, constitutes an informed source of guidance. Sangamon County Sheriff’s Dep’t, 2009 WL 1011986, at *4; Abrahamson, 153 Ill. 2d at 98. B. Statutory scheme The legislature created the General Assembly Retirement System to provide retirement annuities and other benefits for members of the General Assembly, certain other elected officials, and their beneficiaries. 40 ILCS 5/2-101 (2008). The System’s funds and property form a trust that is separate from all other entities. Id. The term “member” is defined as “[m]embers of the General Assembly of

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this State including persons who enter military service while a member of the General Assembly and any person serving as Governor, Lieutenant Governor, Secretary of State, Treasurer, Comptroller, and Attorney General for the period of service in such office.” 40 ILCS 5/2-105 (2008) (App. at A33).3 “Service” means “the period beginning on the day when a person first became a member, and ending on the date under consideration, excluding all intervening periods of nonmembership following resignation or expiration of any term of office.” 40 ILCS 5/2-110(A) (2008) (App. at A34). “Service” also includes the total period of time for which the participant is elected as a member or officer, even though he or she does not complete the term because of death, resignation, judicial decision, or operation of law, provided that the contributions required for the entire period of office have been made by or on behalf of the participant. 40 ILCS 5/2-110(C) (2008) (App. at A35-A36). The felony forfeiture provision states that “[n]one of the benefits herein provided for shall be paid to any person who is convicted of any felony relating to or arising out of or in connection with his or service as a member.” 40 ILCS 5/2-

On October 1, 1975, when Public Act 79-959 took effect, the Governor, Lieutenant Governor, Secretary of State, Treasurer, Comptroller, and Attorney General became members of the System. 1975 Ill. Laws 2882, 2883; Ill. Rev. Stat ch. 108 1/2, par. 14-143 (1975). Prior to that date, those officers were members of the State Employees’ Retirement System. See Ill.Rev. Stat. ch. 108 1/2, par. 14143 (1973). -13-

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156 (2008) (App. at A37). With only minor differences, the Pension Code contains identical felony forfeiture provisions for each of the various pension funds and systems. See, e.g., 40 ILCS 5/3-147 (2008) (Police Pension Fund); 40 ILCS 5/14-149 (2008) (State Employees’ Retirement System); 40 ILCS 5/18-163 (2008) (Judges’ Retirement System). C. The Board of Trustees correctly concluded that forfeiture of all of Ryan’s pension benefits is consistent with the intent of the legislature expressed through the plain language of the felony forfeiture provision. The Board correctly determined that Ryan forfeited all of his retirement benefits even though he committed the crimes that led to his felony convictions while he held the offices of Secretary of State and Governor. The Board’s decision is based on the plain language of the felony forfeiture provision, which states that “[n]one of the benefits herein provided for shall be paid to any person who is convicted of any felony relating to or arising out of or in connection with his or her service as a member.” 40 ILCS 5/2-156 (2008). Statutory construction requires courts to ascertain and give effect to the intent of the legislature. Wade, 226 Ill. 2d at 509; Shields, 204 Ill. 2d at 493. The plain language of the statute is the most reliable indicator of the legislature’s intent, and where statutory language is clear, it must be applied as written. See Sangamon County Sheriff’s Dep’t, 2009 WL 1011986, at *5 (meaning of “nonmanagerial or nonsupervisory employee” was clear for purposes of employer

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liability for sexual harassment); Shields, 204 Ill. 2d at 494 (statutory reference to “refund” of pension contributions was unconditional and meant refund of all contributions). The Board correctly found that “the plain language of Section 2-156 mandates the forfeiture of all Retirement Annuity provided by the System where a nexus exists between the felony conviction and the participant’s official duties, regardless of whether the participant held distinct offices or positions with the State.” (C. 287). Thus, because Ryan’s felonies were connected with his service to the State while a member of the System, application of the plain language was triggered and Ryan was entitled to “[n]one of the benefits” that otherwise would have been paid to him. Although pension statutes are liberally construed in favor of the annuitant (see, e.g., Shields, 204 Ill. 2d at 494), this canon of construction has its bounds (Mattis v. State Univ. Ret. Sys., 212 Ill. 2d 58, 76 (2004)). If legislative intent is obvious from the language used, “that intention must be made effective, and the judiciary will not be warranted in giving the act a meaning not expressed in it.” Robbins v. Bd. of Trustees of the Carbondale Police Pension Fund, 177 Ill. 2d 533, 545 (1997). Thus, the liberal construction canon does not prevail over the plain language of the statute. Roselle, 232 Ill. 2d at 552-53. The felony provision mandates the forfeiture of all benefits that Ryan

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earned as a “member,” meaning benefits that accrued from his service for the State in any of the listed positions, not just those directly related to his criminal conduct. The General Assembly did not limit application of the felony forfeiture provision to any particular state office or position and did not make each listed elected office a separate, independent entity for purposes of determining the extent of the forfeiture. Rather, as the Board concluded, based on the plain language of the statute, it is clear that no benefits provided by the System are to be paid where a nexus exists between the felony conviction and the member’s official duties, regardless of the particular positions or offices that were held at the time of the member’s criminal conduct (id.). D. The Board of Trustees’ decision is consistent with relevant case law. The Board correctly found that the termination of all of Ryan’s pension benefits was consistent with other decisions that have examined whether a felony conviction results in a full forfeiture of benefits (S.R. C. 287-89). The decision in Wells v. Bd. of Trustees of the Ill. Mun. Ret. Fund, 361 Ill. App. 3d 716 (2nd Dist. 2005), appeal denied, 217 Ill. 2d 627 (2006), is directly on point. There, Wells was employed by the Village of Antioch from 1974 through 2001 in a number of positions: laborer; water and sewer department foreman; director of the public works department; and village administrator. Id. at 718. He was convicted of felonies relating to his position as village administrator, and the

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IMRF Board terminated all of his pension benefits. Id. at 718-19. The appellate court affirmed the Board’s decision and rejected Wells’ argument that he should have to forfeit only those benefits related to the village administrator position. Id. at 721-23. The Wells court concluded that the term “service as an employee” in section 7-219 of the Pension Code (40 ILCS 5/7-219) did not limit the application of the statute to particular positions held within the scope of one’s service to a single employer. 361 Ill. App. 3d at 721-23. According to the court, if the legislature had intended the statute to operate as Wells suggested, “it could have easily written ‘related to one’s job’ or ‘related to one’s position[,]’” but it did not. Id. at 722. Also, the court found that plaintiff’s view of the statute would be difficult to apply where one employer is involved, because the employee may not have been in a situation to commit the felony had it not been for the earlier positions he held with that same employer. Id. Thus, the court concluded, “section 7-219 applies to whatever benefits are generated by service to a single employer regardless of the particular positions held by the employee during the employment.” Id. at 723. The Wells rationale and result apply directly to Ryan’s situation. The various offices that Ryan held over the years were all part of one pension fund, and his service was all for one governmental entity, the State of Illinois. Like the plaintiff in Wells, Ryan held various positions in the service of a single entity. As

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the Board correctly concluded in accordance with Wells, the key factor “rests on the singularness of the employer.” (S.R. C. 290). Like the plaintiff in Wells, Ryan must forfeit all of the benefits he earned as a member of the System, despite the fact that those benefits accrued from multiple positions. As the Board found, “[b]ased on Wells, section 2-156 mandates forfeiture of all of a public officials’s pension benefits generated by service to a single governmental entity where a nexus exists between the felony conviction and any of the public official’s duties to that entity, regardless of the position held.” (S.R. C. 289). The Board also examined two additional cases – Taddeo v. Bd. of Trustees of the Ill. Mun. Ret. Fund, 216 Ill. 2d 590 (2005), and Grever v. Bd. of Trustees of the Ill. Mun. Ret. Fund, 353 Ill. App. 3d 263 (2nd Dist. 2004), appeal denied, 217 Ill. 2d 561 (2005) – but correctly concluded that they did not require a different result. In Taddeo, this Court addressed whether a participant in the IMRF who earned concurrent service credits based on simultaneous employment with two separate municipalities forfeited his right to all of his pension benefits with both employers when he was convicted of a felony relating to only one of the positions. 216 Ill. 2d at 595-600. Taddeo, a Proviso Township supervisor from 1969 through 1999 and mayor of Melrose Park from 1972 until 1997, was convicted of felonies

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based on crimes he committed as mayor during the period from 1988 to 1994. Id. at 592. This Court held that Taddeo forfeited the benefits that accrued when he was employed by Melrose Park but not those related to his employment with Proviso Township. Id. at 596-600. The decision was based on the fact that Taddeo worked for “two separate participating municipalities” in the IMRF. Id. at 598. Noting that sections 7-203 and 7-204 of the IMRF (40 ILCS 5/7-203, 7-204) treat each participating municipality as an independent employer within the fund, the court stated that Taddeo “in essence, earned two completely separate pensions – one for his service as township supervisor, and one for his service as mayor” of Melrose Park. Taddeo, 216 Ill. 2d at 598. Because two employers were involved and because there was no nexus between the criminal conduct and Taddeo’s services as Proviso Township supervisor, he did not have to forfeit the pension benefits associated with that employer. Id. The citizens of Proviso Township suffered no breach of the public trust and Taddeo’s Proviso pension therefore remained intact. This same distinction between employers in the IMRF also resulted in a partial forfeiture of pension benefits in Grever, where the plaintiff served in various positions for separate participating municipalities: Ela Township supervisor from 1981 to 2001; Lake County Board member from 1990 to 2000;

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and Forest Preserve District commissioner from 1990 to 2000. Id. at 264. He was convicted of felonies relating solely to his township supervisor position. Id. The appellate court concluded that Grever should forfeit only those pension benefits accrued from the township position, finding that “a conviction of a felony in connection with service to a particular municipal employer results in the forfeiture of benefits earned only from that particular employment relationship.” Id. at 267. Under the reasoning of Taddeo and Grever, pension benefits are not forfeited to the extent they are earned in the service of a governmental employer different from the one to which the officer’s felony convictions relate. Thus, Wells held that a felony conviction results in a forfeiture of all benefits when the employee is in service to one employer, regardless of the positions held. 361 Ill. App. 3d at 722. And the Taddeo and Grever decisions also rested on the explicit provisions in the IMRF that treat municipalities as independent employers within the pension fund. See 40 ILCS 5/7-203, 5/7-204 (2008). The Board’s decision is consistent with these cases because Ryan belonged to one retirement system in service to the State of Illinois – the sole employer participating in the System. Nothing in the portion of the Code governing the System either implicitly or explicitly treats the various elected offices as separate entities for the purpose of pension credits or payments or for forfeiture of benefits upon a service-related felony conviction.

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E.

Public policy considerations support the Board’s termination of all of Ryan’s pension benefits. Not only is the Board’s decision consistent with the plain language of the

Code and relevant case law, but it also advances important public policy aims. The felony forfeiture provisions “have been enacted pursuant to the legislature’s power ‘to deter felonious conduct in public employment by affecting the pension rights of public employees convicted of a work-related felony.’” Devoney v. Ret. Bd. of the Policemen’s Annuity & Benefit Fund, 199 Ill. 2d 414, 418 (2002) (quoting Stillo v. State Ret. Sys., 305 Ill. App. 3d 1003, 1007 (1st Dist. 1999)). The provisions are intended to discourage official malfeasance by denying the public servant convicted of breach of the trust the retirement benefits to which he otherwise would have been entitled. Kerner v. State Employees’ Ret. Sys., 72 Ill. 2d 507, 513 (1978). The provision also is intended to protect the public’s right to conscientious service from government officials. Id. A forfeiture provision also protects public funds and preserves respect for government service. See MacLean v. State Bd. of Ret., 733 N.E.2d 1053, 1063 (Mass. 2000); see also 40 ILCS 5/2-124 (2008) (State appropriates funds to contribute to the System); 40 ILCS 5/2-125 (2008) (State has obligation to make required contributions). The forfeiture of all of Ryan’s pension benefits is the only outcome consistent with these consistent with the policies underlying the felony forfeiture provision. -21-

Each time Ryan was elected to any of the various positions, he remained at all times within the purview of the System and the applicable statutory provisions, including the felony forfeiture provision. By participating as a member, he accepted not only the benefits of the System, but the mandate that his pension would be lost if he were convicted of felonies related to his service to the State as a member of the System. He cannot now complain that forfeiture is unjust or unfair. No unfairness exists where the General Assembly gave notice to Ryan when he was first elected to that body that future abuses of the public trust in the form of service-related felony convictions would deprive him of his pension. In an analogous case from Pennsylvania, a judge became a member of the State Employees’ Retirement System when he entered office in 1972. Shiomos v. State Remployees’ Ret. Bd., 626 A.2d 158, 160 (Pa. 1993).4 He began his second term of office in 1982, retired in 1984, and then assumed status as a senior judge. He was later convicted of extortion for conduct he committed while serving as a senior judge. The pension board terminated his entire pension as of the date of his conviction, and he appealed. One of his arguments was that only the benefits that accumulated after the start of his second term should be forfeited.

The Pennsylvania statute reads: “Notwithstanding any other provision of law, no public official or public employee . . . shall be entitled to receive any retirement or other benefit or payment of any kind . . . if such public official or public employee is convicted or pleads guilty or no defense to any crime related to public office or public employment.” Pa. Cons. Stat. § 1313(1) (2007). -22-

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The Pennsylvania Supreme Court rejected this argument for reasons that apply with equal force here: As a reasonable condition of public employment, the employee reaffirms his commitment to perform his job with honesty and integrity every time he or she begins a new term of office . . . . Thus, whether or not a public employee’s right to receive retirement benefits has vested, or he or she is in actual receipt of benefits, all previous accumulated rights to receive such benefits are subject to forfeiture by and through the “renewed” agreement which is formed each time a person chooses to become a “public official” as defined by [the pension statute]. Shiomos, 626 A.2d at 162-63. The Shiomos court concluded that the forfeiture of all benefits was a just result, holding that [i]t is neither unconscionable nor unreasonable to require honesty and integrity during an employee’s tenure in public service. Nor is it violative of the Pennsylvania Constitution to provide that at every new term of employment a public official or employee renews and amends his or her pension contract to include the new public service and to place at risk that which may have already been earned. Such is the nature of the public employment agreement. Id. at 163. This Court recognizes that a public official has an obligation to carry out the public trust honorably and in good faith. People v. Barr, 83 Ill. 2d 191, 210 (1980). Ryan knew when he became a member of the System in 1972 that he would forfeit his pension if he were convicted of a felony related to his service as a -23-

member. There surely is no unfairness in applying that long-standing provision to him now, and indeed it would be an entirely artificial exercise to distinguish among different periods of service to the same public employer. F. The appellate court’s decision should be reversed because it was based on a misreading of the Code and erroneously distinguished the cases relied on by the Board. The appellate court offered essentially two reasons for reversing the Board’s decision. First, it went beyond the plain language and read a limitation on the felony forfeiture provision into the phrase “for the period of service in such office” in the definition of “member.” Second, the court rejected the Board’s conclusion that its decision was consistent with Taddeo, Grever, and Wells. The appellate court erred on both scores. 1. The appellate court’s conclusion that the definition of “member” limits the felony forfeiture provision is unwarranted.

The court focused on the phrase “for the period of service in such office” in the definition of “member” to conclude that Ryan must forfeit only those benefits that accrued while he was Governor and Secretary of State, the positions he held when he committed his crimes. Ryan, 388 Ill. App. 3d at 168. According to the appellate court, this phrase narrows the scope of the word “member,” which in turn limits the forfeiture provision. As shown above, the Board’s decision was based on the plain language of the felony forfeiture provision. The appellate court departed from that plain -24-

language by reading a limitation into the provision that the legislature did not intend. Section 2-156 clearly states that none of the benefits shall be paid when a felony conviction relates to, arises out of, or is connected with the person’s service as a member. 40 ILCS 5/2-156 (2008). But nothing in section 2-156 or any other provision of the Code limits the forfeiture to those specific offices held while the crimes were committed. See Madison Two Assoc. v. Pappas, 227 Ill. 2d 474, 494 (2008) (court may not read into a law limitations not intended by legislature). The court’s analysis also runs afoul of the principles announced by this Court in Shields, which involved the meaning of the word “refund” in the context of contribution refunds under the Pension Code for a participant’s service-related felony conviction. 204 Ill. 2d at 492. In determining the amount of the refund, the pension board looked to another section of the statute and determined that the refund amounted to the difference between a participant’s contributions and the sum of annuity payments made prior to the conviction. Id. This Court rejected that decision, based on statutory construction principles that the appellate court ignored here. Specifically, the Shields court concluded that because the statutory reference to a refund was unconditional, clear, and unambiguous, it should have been applied as written to require a refund of all contributions made, without reliance on any other statutory provision. Id. at 496-97. The Shields court would

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not presume that the legislature intended to limit the pension provision because it is not a court’s role to restrict or enlarge the meaning of unambiguous language. Id. at 497. The Board’s application of the unconditional language in section 2-156 is consistent with the principles announced in Shields, but the appellate court’s decision appears to have disregarded them. The language in the forfeiture provision is clear, unambiguous, and unconditional, yet the appellate court improperly limited the scope of that provision by looking to the meaning of the phrase “for the period of service in such office” in the definition of “member.” Even assuming for the sake of argument that the phrase “service as a member” creates an ambiguity in section 2-156, the appellate court erred in construing the phrase as a limitation on the felony forfeiture provision. The court first looked to the definition of member: “Members of the General Assembly of this State including persons who enter military service while a member of the General Assembly and any person serving as Governor, Lieutenant Governor, Secretary of State, Treasurer, Comptroller, or Attorney General for the period of service in such office.” 40 ILCS 5/2-105 (2008). From there it looked to the phrase “period of service in such office” and concluded that it “was drafted in the singular and, thus, limits the scope to a specific office held.” Ryan, 388 Ill. App. 3d at 168. The court then stated that “[w]hen this definition is read alongside

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section 2-156, we find that the felony conviction ‘relating to or arising out of or in connection with his or her service as a member’ must be linked to the ‘the [sic] period of service in such office.’” Id. The appellate court identified an ambiguity where none exists. Contrary to the court’s conclusion, the phrase “for the period of service in such office” simply refers to a member’s eligibility in the pension fund; it is not a limitation on the felony forfeiture provision. Indeed, section 2-110(A) states that “‘service’ means the period beginning on the day a person first became a member, and ending on the date under consideration, excluding all intervening periods of nonmembership following resignation or expiration of any term of office.” 40 ILCS 5/2-110(A) (2008). This definition makes clear that the General Assembly treats membership in the System as an undivided whole, regardless of the various offices held, with breaks in membership only for periods when the state official does not hold any qualifying office. Likewise, another definition of “service” states that “‘[s]ervice’ includes the total period of time for which the participant is elected as a member or officer, even though he or she does not complete the term because of death, resignation, judicial decision, or operation of law, provided that the contributions required under this Article for such entire period of office have been made by or on behalf of the participant.” 40 ILCS 5/2-110(C) (2008). Based on this definition, the

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phrase “for the period of service in such office” in the definition of “member” simply defines eligibility and the period of time that is credited toward membership in the System. It makes plain that a state elected official is a member of the System for the entire term of his elected office, so long as the necessary contributions are made. Thus, an elected official who leaves office early will continue to be a “member” for the entire elected period, provided he makes the necessary contributions. Accordingly, the phrase “for the period of service in such office” defines the period of membership or eligibility in the System, but in no way purports to create distinct, severable units of membership for purposes of the felony forfeiture provision. As elected state officeholders who have the opportunity to remain members for the duration of their elected terms, regardless of whether they leave office early, System members are unique among pension fund participants. In contrast, for example, a state employee is a member of the State Employees’ Retirement System (“SERS”) only so long as he receives a salary. 40 ILCS 5/14-103.05(a) (2008). And, most “employees” do not become members of SERS until they have completed a qualifying period of six months of continuous service. Id. Because members of the System are officials elected to fill a specific term of office, their membership is not defined by receipt of a salary, and they have no qualifying period before they become members. The General Assembly has

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provided state elected officials the opportunity to remain members of the System, even if they leave office early, so long as they make the necessary contributions for the entire period of office. Because of this unique aspect of the System, as compared to other pension funds, the legislature needed to insert the phrase “for the period of service in such office” in the definition of the word “member.” The appellate court’s attempt to ascribe a meaning to the phrase and read it as a limitation on the felony forfeiture provision should be rejected because that was not the legislative intent. Had the General Assembly wanted the phrase “for the period of service in such office” to limit the felony forfeiture provision, as the appellate court held, it would have added that language directly to the provision, rather than to the section defining membership in the System. If the provisions governing membership or felony forfeitures were ambiguous, it then would be proper to consider legislative history. County of DuPage, 231 Ill. 2d at 604. And the history cannot be squared with the appellate court’s decision here. The transfer of the constitutional offices from SERS to the System in October 1975 had its origins in House Bill 2784, which eventually became Public Act 79-959 (see infra p. 13, n.3). Senator Egan offered an amendment to the bill, which accomplished four things: It enumerates the offices and further provides that the persons named to be elected by vote of the people of the whole State. One, two, it limits the salary of officers for pension purposes to the salary of the -29-

highest paid officer of the General Assembly. Number three, it provides for the transfer and validation of credit for the officers elected and number four, it provides for the termination of their participation in the [SERS]. Senate, 79th Ill. Gen. Assem., 80th Leg. Day, p. 99 (June 25, 1975) (Sen. Egan). Other statements reflected that the “real reason” the constitutional offices were being transferred was to obtain a larger pension (Id., p. 103 (June 25, 1975) (Sen. Smith)) because they “presently don’t have a plan that’s sufficient for them.” (Id., p. 116 (June 25, 1975) (Sen. Newhouse)). Although there was some resistance in the Senate (e.g., “[I]f they want to join the Legislative Pension Plan they should run for the Legislature.” (Id., p. 101 (June 25, 1975) (Sen. Savickas)); “What is the need for this compromise? Do they not now have a pension system of their own?” (Id., p. 105 (June 25, 1975) (Sen. Wooten)); “[I]f [SERS] is not good enough for our officials, then, obviously, [SERS] is not [] good for the common employees.” (Id., p. 116 (June 25, 1975) (Sen. Savickas))), the amendment passed (Senate, 79th Ill. Gen. Assem., 81st Leg. Day, p. 314 (June 26, 1975). When the bill returned to the House, Representative Telscer explained that the Senate amendment “provides that the maximum benefit which . . . an . . . official may receive cannot be higher than the salary of the highest paid officer in the System, and that . . . after two years as an officer, the officers have the option . . . to pay in another two years to receive the four years credit[.]” House of

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Representatives, 79th Ill. Gen. Assem., 101st Leg. Day, p. 108 (June 28, 1975) (Rep. Telcser). The House voted 124 to 4 in favor of the amendment. Id. As the legislative discussions make clear, the reason for the transfer of the constitutional officers from SERS to the System was to upgrade their pensions, certainly not to protect them from application of the felony forfeiture provision. The legislative debates not only show that the appellate court’s conclusion was wrong, but they also point out the weakness in Ryan’s position. In arguments made to the circuit court, Ryan found it significant that the constitutional officers were moved from SERS to the System because that “suggests strongly that these are separate and distinct offices and have to be treated as such.” (R. Vol 2, at 10). But there was absolutely no mention of section 2-156 in the debates and no suggestion that the transfer created separate memberships for purposes of limiting the application of the felony forfeiture provision. If, as Ryan believed, the transfer had the purpose of providing a new felony forfeiture protection to the constitutional officers, surely such a significant change would have been mentioned by someone during the debates on the bill. Yet there was never any suggestion that the amendment had either that purpose or effect. Thus, given that legislative debates may be consulted for determining the meaning of a statute, these debates establish that the appellate court erred in holding that the legislature intended to create separate membership divisions for purposes of section 2-156.

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2.

The appellate court erred in finding that Taddeo and Grever required reversal of the Board’s decision and that Wells was distinguishable.

As previously shown, the Board correctly found that the termination of all of Ryan’s pension benefits was not inconsistent with Taddeo, Grever, and Wells. On the other hand, the appellate court determined that Taddeo and Grever dictated reversal and that Wells was distinguishable. The appellate court erred. The court stated that the Taddeo and Grever decisions mandated reversal of the Board’s decision because those courts construed “the pension disqualification statutes liberally in favor of the pensioner and only found disqualification of the pension when a connection was found between the felony conviction and the pensioner’s employment.” Ryan, 388 Ill. App. 3d at 167. The appellate court also found that the Taddeo court merely “considered” the fact that the employee had earned a pension from two separate municipalities and focused instead on the connection between the felonies and the employment. Id. On the contrary, the Taddeo decision was heavily influenced by the fact that the plaintiff was employed by two separate municipalities and that municipalities are treated as separate entities under the IMRF. 216 Ill. 2d at 598. The court stated that section 7-203 of the IMRF provides that “‘separate reserves shall be maintained for each participating employee in such detail as is necessary to administer all benefits provided herein, and to segregate accurately the separate

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liabilities of each participating municipality and its instrumentalities, or of any participating instrumentality, with respect to each participating employee.’” Id. at 598-99 (quoting 40 ILCS 5/7-203). The court also recognized that section 7-204 of the IMRF provides that ‘“each participating municipality and its instrumentalities, and each participating instrumentality, shall be treated as an independent unit within the fund.’” Id. at 599 (citing 40 ILCS 5/7-204). Because municipalities participating in the IMRF are treated as separate entities, this Court found that Taddeo’s pension was severable for purposes of the felony forfeiture provision. The Grever decision also was influenced by the fact that the “individual earns benefits from several employers.” 353 Ill. App. 3d at 267. The point of these cases is that, for the IMRF, since each municipality contributes to the pension fund for its own employees, the breach of the public trust and the forfeiture of benefits relate back to the individual contributing municipality. For the System, contributions are made by only one entity – the State (see 40 ILCS 5/2-124 (2008) (“The State shall make contributions to the System[.]”)), and the official malfeasance and the resulting forfeiture relate to the State as a whole. Through his felonious conduct while in service to the citizens of Illinois, Ryan knowingly placed at risk all of the pension benefits he had earned and to which he otherwise would have been entitled. Accordingly, because his

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service throughout his membership in the System was to one entity and not multiple contributing employers like the plaintiffs in Taddeo and Grever, the State should not have to provide him with any pension. The very people whose trust Ryan betrayed for personal gain should not now be required to fund his retirement. The appellate court below failed to recognize both the importance of the statutory scheme to the reasoning in Taddeo and Grever and the significant differences between the IMRF statute and the portion of the Code pertaining to the System (or any other public pension system). As the Board correctly concluded, its decision to terminate Ryan’s entire pension was consistent with Taddeo “in that all pensions from the same employer, despite different positions held with that employer and despite the misconduct in a single such position with that employer, are forfeited.” (S.R. C. 289). Here, there was but one employer – the State of Illinois – and, according to Taddeo, that is the relevant fact in applying the felony forfeiture provision to all of the pension benefits. The Board’s decision represents a correct reading and application of both Taddeo and Grever. Regarding Wells, the appellate court found that the case was distinguishable because the pension statute at issue there “look[ed] at a member’s ‘service as an employee,’ [and] section 2-156 applies to ‘service as a member.’” Ryan, 353 Ill. App. 3d at 168. This is a distinction without a difference. Wells is no less controlling of this case because it involved an “employee” who forfeited his

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pension rather than a pension fund “member” subject to a substantively identical forfeiture provision. This Court should not attach any significance to the use of different phrases in the various pension forfeiture provisions beyond the General Assembly’s need to use terms that best describe the shared characteristics of the members of each fund. For example, in the IMRF and SERS felony forfeiture provisions, “employee” is used to describe those who receive earnings as payment for the performance of personal services or official duties rendered to the municipalities or Departments of the State. See 40 ILCS 5/7-109(a) (2008) (IMRF “employee” is one who “[r]eceives earnings as payment for the performance of personal services or official duties”); 40 ILCS 5/14-103.05(a) (2008) (SERS “employee” means “[a]ny person employed by a Department who receives salary for personal services rendered to the Department”). Further, the felony forfeiture provision relevant to the Judges’ Retirement System applies to “service of a judge” (40 ILCS 5/18-163 (2008)), the provision relating to the Teachers’ Retirement System uses the phrase “service as a teacher” (40 ILCS 5/16-199 (2008)), and so on. The General Assembly chose the term “service as a member” in the System’s felony forfeiture section not to narrow the application of the provision, but to best describe the participants, all of whom hold elected offices established by the Illinois Constitution and, therefore, do not neatly fit within the term

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“employee.” See Ill. Const. arts. IV, V. In fact, unlike most other parts of the Pension Code, that portion relating to the System does not use or define the words “employer” or “employee” at all, and such terms in the context of the System would be inapt. See, e.g., 40 ILCS 5/14-103.05 (2008) (SERS definition of “employee”); 40 ILCS 5/15-106 (2008) (State Universities Retirement System definition of “employer”). Contrary to the appellate court’s conclusion, beyond the legislature’s use of the term “member” to describe participants in the System, no significance can attach to this term. Had the General Assembly intended to treat each of the member offices in the System as a separate entity, it easily could have included such a limitation in the statute, as it did in the IMRF. See 40 ILCS 5/7-204 (2008) (each municipality “shall be treated as an independent unit within the fund”). It made no such express or implied limitation. Reading the statute as a whole, which this Court must do (see Ultsch v. Ill. Mun. Ret. Fund, 226 Ill. 2d 169, 181 (2007)), it is clear that the General Assembly intended to treat members’ elected terms as one, undivided period of service to the people of the Illinois during which the officeholder is bound by both the System’s benefits and its obligations, including the felony forfeiture provision. Section 2-156 of the Pension Code unambiguously requires a forfeiture of all benefits of a member of the System who is convicted of a felony associated

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with his service as a member. Because Ryan’s felony convictions related to conduct he committed while he was a member of the System in service to the State of Illinois, he forfeited his entire pension. The appellate court’s decision in Ryan’s favor should be reversed.

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CONCLUSION For these reasons, the Defendants-Appellants, the Board of Trustees of the General Assembly Retirement System and the individual Members of the Board, respectfully request that this Honorable Court affirm the Board’s decision terminating all of George Ryan’s pension benefits based on his felony convictions and reverse the appellate court’s decision. Respectfully submitted, LISA MADIGAN Attorney General State of Illinois MICHAEL A. SCODRO Solicitor General 100 W. Randolph St., 12th Floor Chicago, Illinois 60601 (312) 814-3312 Attorneys for Defendants-Appellants JAN E. HUGHES Assistant Attorney General 100 W. Randolph St., 12th Floor Chicago, Illinois 60601 (312) 814-2129

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CERTIFICATE OF COMPLIANCE I certify that this brief conforms to the requirements of Rule 341(a) and (b). The length of this brief, excluding the pages containing the Rule 341(d) cover, the Rule 341(h)(1) statement of points and authorities, the Rule 341(c) certificate of compliance, the certificate of service, and those matters to be appended to the brief under Rule 342(a), is 38 pages.

JAN E. HUGHES Assistant Attorney General

APPENDIX

TABLE OF CONTENTS TO THE APPENDIX 1. Ryan v. Bd. of Trustees of the Gen. Assembly Ret. Sys., 388 Ill. App. 3d 161 (1st Dist. 2009) . . . . . . . . . . . . . . . . . A1 – A9 Circuit Court Memorandum Opinion, entered May 31, 2007 . . A10 – A20 Decision of the Board of Trustees, dated December 6, 2006 . . . . . A21-A32 40 ILCS 5/2-105 (2008) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A33 40 ILCS 5/2-110 (2008) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A34-A36 40 ILCS 5/2-156 (2008) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A37 40 ILCS 5/7-203 (2008) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A38 40 ILCS 5/7-204 (2008) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A39 Table of Contents to the Record on Appeal . . . . . . . . . . . . . . . . . . A40-A44

2. 3. 4. 5. 6. 7. 8. 9.

STATE OF ILLINOIS COUNTY OF COOK

) ) SS. )

PROOF OF SERVICE The undersigned, being first duly sworn upon oath, deposes and states that three copies of the foregoing Brief of the Defendants-Appellants were served upon the below-named party by depositing such copies in the United States mail at 100 West Randolph Street, Chicago, Illinois, in an envelope bearing sufficient first class postage on July 2, 2009, before 5:00 p.m.

Kyle P. De Jong Winston & Strawn LLP 35 West Wacker Drive Chicago, IL 60601

SUBSCRIBED and SWORN to before me this 2nd day of July, 2009.

NOTARY PUBLIC

No. 108184 IN THE SUPREME COURT OF ILLINOIS GEORGE H. RYAN, SR., Plaintiff-Appellee, v. THE BOARD OF TRUSTEES OF THE GENERAL ASSEMBLY RETIREMENT SYSTEM OF ILLINOIS, REP. KURT M. GRANBERG, SEN. JAMES CLAYBORNE, SEN. DON HARMON, REP. RICHARD T. BRADLEY, SEN. WILLIAM BRADY, REP. LEE DANIELS, and REP. PHILIP COLLINS, in their official capacities, Defendants-Appellants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) On Appeal from the Appellate Court of Illinois, First Judicial District No. 1-07-1601

There on Appeal from the Circuit Court of Cook County, Illinois, County Department, Chancery Division No. 06 CH 28340

The Honorable MARTIN S. AGRAN, Judge Presiding.

NOTICE OF FILING BY MAIL TO: Kyle P. De Jong Winston & Strawn LLP 35 West Wacker Drive Chicago, IL 60601

PLEASE TAKE NOTICE that I filed the original and twenty copies of the Brief of the Defendants-Appellants with the Clerk of the Supreme Court, Supreme Court Building, 200 E. Capitol Ave., Springfield, Illinois, 62701, by depositing the same in the U.S. mail at 100 West Randolph Street, Chicago, Illinois, with proper postage prepaid, before 5:00 p.m. on July 2, 2009. Three copies of that Brief are hereby served upon you. LISA MADIGAN Attorney General State of Illinois

By: JAN E. HUGHES Assistant Attorney General 100 W. Randolph St., 12th Floor Chicago, Illinois 60601 (312)-814-2129

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