In Illinois, the state commission and state courts declined to order refunds primarily because of the filed-rate doctrine, which prohibits retroactive revisions to rates that a government regulatory body has approved. See Illinois Public Telecommunications Association v. Illinois Commerce Commission, No. 1–04–0225, 361 Ill.App.3d 1081, 331 Ill.Dec. 532, 911 N.E.2d 2 (Ill.App.Ct. Nov. 23, 2005). In New York, the state commission and state courts have thus far declined to grant refundsbut have left the question open pending resolution of the independent payphone providers' petition in this case.

In Illinois, the state commission and state courts declined to order refunds primarily because of the filed-rate doctrine, which prohibits retroactive revisions to rates that a government regulatory body has approved. See Illinois Public Telecommunications Association v. Illinois Commerce Commission, No. 1-04-0225 (Ill. App. Ct. Nov. 23, 2005). In New York, the state commission and state courts have thus far declined to grant refunds but have left the question open pending resolution of the independent payphone providers' petition in this case.

¶5 This court affirmed the Commission's 2003 decision, holding that the Association's members were not entitled to refunds because Illinois law barred refunds on tariffed rates. Illinois Public Telecommunications Ass'n v. Illinois Commerce Comm'n, No. 1-04-0225 (Nov. 23, 2005) (unpublished order pursuant to Illinois Supreme Court Rule 23). The Illinois Supreme Court and the United States Supreme Court subsequently denied the Association's requests to review our decision.