Chiakulas v. Department of Mental Health & Developmental Disabilities

1 Citing case

  1. Martin v. Dept. of Prof. Regulation

    672 N.E.2d 267 (Ill. App. Ct. 1996)   Cited 10 times
    Stating that even if the Director of the Department of Professional Regulation had been a necessary party, under Armstead, the court would apply the newly amended section 3-107 and allow plaintiff the opportunity to name and serve the Director in an action for administrative review

    EE, 262 Ill. App.3d at 551. In Chiakulas v. Department of Mental Health Developmental Disabilities, 240 Ill. App.3d 84, 608 N.E.2d 114 (1992), a facility manager decided to transfer plaintiff to another facility, and plaintiff appealed directly to the Director of the Department. Thus, the Director in Chiakulas did not merely affirm a committee's recommendation but instead personally reviewed the decision of the facility manager.