First District Illinois Appellate Court Reaffirms Higher Standard for Pleading Willful and Wanton Misconduct

The Appellate Court for the First District of Illinois has reaffirmed that a complaint’s “bare”bones” allegations of willful and wanton misconduct are insufficient to overcome the immunity provided to governmental entities by the Tort Immunity Act. The Local Governmental and Governmental Employees Tort Immunity Act, 745 ILCS 10/1 et al., (the “Tort Immunity Act”) protects local governmental entities and their employees from liability for negligence committed during the exercise of their duties…