Illinois courts have long held, however, that forfeiture is "a limitation on the parties and not on the courts." In re Madison H., 215 Ill. 2d 364, 371 (2005); People ex rel. Resnik v. Curtis & Davis, Architects & Planners, Inc., 78 Ill. 2d 381, 384 (1980); see also Goral v. Illinois State Board of Education, 2013 IL App (1st) 130752, ¶ 16. A reviewing court may look beyond considerations of waiver in order to maintain a sound and uniform body of precedent or where the interests of justice so require.
¶ 23 Ordinarily, the law to be applied is the law that is in effect at the time of the administrative action at issue. See Goral v. Illinois State Board of Education, 2013 IL App (1st) 130752, ¶ 27, 378 Ill.Dec. 85, 3 N.E.3d 365 (the date of the administrative body's decision or action is the relevant date in determining which version of a statute applies). Here, the action challenged by Frederick was the Department's revocation of his FOID card in 2013, not its 2011 issuance of that card.
However, Rafti did not object to the consideration of this evidence during the hearing; thus, he has forfeited any argument as to whether the evidence was properly considered. See Goral v. Illinois State Board of Education, 2013 IL App (1st) 130752, ¶ 31 (failure to object to evidence during the hearing or raise the issue in a complaint for administrative review results in forfeiture). ¶ 28 Rafti also seems to argue that expert testimony was required to support the Department's conclusion that Rafti was qualified to work as a paralegal.