Piasa Armory, LLC v. Raoul

Summary

The court held that the statutory limitation requiring constitutional actions against the State to be brought in Cook or Sangamon County was not unconstitutional as applied to this business plaintiff. Applying the Mathews balancing framework, the court concluded that the asserted inconvenience of litigating in Sangamon County did not deny a meaningful opportunity to be heard, particularly because the underlying facial challenge would likely be resolved without trial and remote appearances were available. The court therefore reversed the circuit court’s summary judgment for the plaintiff and remanded the cause.