Feb. 16, 2011)), which permits an extension of time to file a pleading for good cause shown, applies to the filing of a notice of rejection of an arbitrator's award. Ianotti v. Chicago Park District, 250 Ill.App.3d 628, 631 (1993). Local Rule 25.11 was subsequently amended, effective April 1, 2021, allowing a party to reject an arbitration award within 14 calendar days after receiving notice of the arbitration award.

¶ 13 In Ianotti v. Chicago Park District, 250 Ill.App.3d 628 (1993), the plaintiff filed a rejection to an arbitration award 37 days after the award had been filed. Id. at 629-30. The plaintiff asserted that he filed the rejection late because of an inadvertent error.

For the reasons explained above, Rule 93 had no application in this case. In Ianotti v. Chicago Park District, 250 Ill. App. 3d 628, 629 (1993), the plaintiff filed a notice of rejection of an arbitrator's award seven days late. The plaintiff claimed his failure to file his notice of rejection on time was the result of an inadvertent error.

¶ 34 Even after the filing deadline has passed, a trial court has the authority under Rule 183 to extend the time for filing a rejection of an arbitration decision for good cause. See, e.g., Stemple v. Pickerill, 377 Ill. App. 3d 788, 794 (2007); Gellert v. Jackson, 373 Ill. App. 3d 149, 151 (2007) ("we see no insurmountable barrier, such as a lack of jurisdiction, to a court's allowing a case to proceed despite a technically untimely rejection of an arbitration decision"); Ianotti v. Chicago Park District, 250 Ill. App. 3d 628, 630-31 (1993). The circuit court may consider "all objective, relevant evidence presented by the delinquent party with respect to why there is good cause for its failure to comply with the original deadline and why an extension of time should now be granted.

" (Emphasis added.) ¶ 17 For these reasons, parties who fail to timely reject an arbitration award or who fail to appear at arbitration hearings are often debarred from contesting the award at all (see, e.g., Liebovich Steel & Aluminum Co. v. Advance Iron Works, Inc., 353 Ill. App. 3d 311, 315 (2004); Hinkle, 303 Ill. App. 3d at 113-15), although the circuit court may in its discretion extend the time for filing the rejection notice upon a showing of good cause (see Ianotti v.Chicago Park District, 250 Ill. App. 3d 628 (1993)). Because the mandatory arbitration program is intended to provide "a feasible vehicle for an early[,] economical and fair resolution of monetary disputes" (Ill. S. Ct. Rs., Mandatory Arbitration, Introductory Comments), limiting a party's ability to contest an award to filing a rejection notice ensures that the process will not be unnecessarily prolonged by attempts to dispute the minutiae of an award.

" (Emphasis added.) ¶ 17 For these reasons, parties who fail to timely reject an arbitration award or who fail to appear at arbitration hearings are often debarred from contesting the award at all (see, e.g., Liebovich Steel & Aluminum Co. v. Advance Iron Works, Inc., 353 Ill.App.3d 311, 315, 288 Ill.Dec. 960, 818 N.E.2d 895 (2004) ; Hinkle, 303 Ill.App.3d at 113–15, 236 Ill.Dec. 578, 707 N.E.2d 705), although the circuit court may in its discretion extend the time for filing the rejection notice upon a showing of good cause (see Ianotti v. Chicago Park District, 250 Ill.App.3d 628, 190 Ill.Dec. 316, 621 N.E.2d 185 (1993) ). Because the mandatory arbitration program is intended to provide "a feasible vehicle for an early[,] economical and fair resolution of monetary disputes" (Ill. S.Ct. Rs., Mandatory Arbitration, Introductory Comments), limiting a party's ability to contest an award to filing a rejection notice ensures that the process will not be unnecessarily prolonged by attempts to dispute the minutiae of an award. Both judicial and private resources are thereby conserved.

George, 299 Ill.App.3d at 890, 234 Ill.Dec. 328, 702 N.E.2d 982. Similarly here, because Swain did not file a rejection of the award, she has no right to proceed to trial and to voluntarily dismiss her case. See also Yanan v. Ewing, 205 Ill.App.3d 96, 102, 150 Ill.Dec. 440, 562 N.E.2d 1243 (1990) (by failing to file a notice of rejection of the arbitration award within the prescribed time period, there was no right to proceed to trial on the plaintiff's complaint); Ianotti v. Chicago Park District, 250 Ill.App.3d 628, 190 Ill.Dec. 316, 621 N.E.2d 185 (1993) (when rejection of arbitration award was filed seven days late, without a showing of good cause for the delay, the trial court properly entered judgment on the arbitration award and denied the plaintiff's motion to voluntarily dismiss the case). ¶ 11 In conclusion, we reverse the trial court's order granting Swain's motion to voluntarily dismiss her case.

Similarly here, because Swain did not file a rejection of the award, she has no right to proceed to trial and to voluntarily dismiss her case. See also Yanan v. Ewing, 205 Ill. App. 3d 96, 102 (1990) (by failing to file a notice of rejection of the arbitration award within the prescribed time period, there was no right to proceed to trial on the plaintiff's complaint); Ianotti v. Chicago Park District, 250 Ill. App. 3d 628 (1993) (when rejection of arbitration award was filed seven days late, without a showing of good cause for the delay, the trial court properly entered judgment on the arbitration award and denied the plaintiff's motion to voluntarily dismiss the case). ¶ 11 In conclusion, we reverse the trial court's order granting Swain's motion to voluntarily dismiss her case.

In Gellert, the plaintiff attempted to file an arbitration award rejection at 4:40 p.m. on the last day of the 30-day window, but the clerk's office had closed at 4:30 despite a circuit court rule requiring clerks' offices to be open until 5 p.m., suggesting that the failure to meet the deadline was not the plaintiff's fault. Cf.Ianotti v.Chicago Park District, 250 Ill.App.3d 628, 631, 190 Ill.Dec. 316, 621 N.E.2d 185 (1993) (“inadvertent error" is not “good cause" under Rule 183 sufficient to justify an extension of the time to file a rejection). In Hornburg and Gellert, another supreme court rule commanded relaxation of the strict requirements of the mandatory arbitration rules.

It should have denied plaintiffs motion only if it rejected his factual allegations. A trial court has the power under Supreme Court Rule 183 (134 Ill. 2d R. 183) to extend the time for filing a rejection of an arbitration decision for good cause, even after the filing deadline is past. Ianotti v. Chicago Park District, 250 Ill. App. 3d 628, 631 (1993). Thus, we see no insurmountable barrier, such as a lack of jurisdiction, to a court's allowing a case to proceed despite a technically untimely rejection of an arbitration decision.