The Illinois Supreme Court is reviewing a case that could significantly impact how police disability benefits are awarded in Chicago, after accepting an appeal from the Retirement Board of the Policemen's Annuity and Benefit Fund of the City of Chicago in *Moreland v. Retirement Board of the Policemen's Annuity and Benefit Fund of the City of Chicago* (2025 IL 131343).
The case involves Donald B. Moreland, a Chicago police officer whose application for duty disability benefits was initially denied by the retirement board. The Cook County Circuit Court affirmed the board's decision, but the Illinois Appellate Court, First District, reversed and remanded the case in 2024.
The procedural history reveals a complex legal dispute over disability benefit eligibility. After Moreland's initial denial, he appealed through the court system, ultimately prevailing at the appellate level. The First District Appellate Court issued its decision in *Moreland v. Retirement Board of the Policemen's Annuity & Benefit Fund* (2024 IL App (1st) 240049), which prompted the retirement board to seek review by the state's highest court.
The appellate court's decision relied heavily on the Illinois Supreme Court's precedent in *Kouzoukas v. Retirement Board of the Policemen's Annuity & Benefit Fund of Chicago* (234 Ill. 2d 446, 2009). In that case, the court established important principles regarding when police officers should be awarded disability benefits. The appellate court determined that under *Kouzoukas*, the retirement board should have awarded Moreland a duty disability pension because the Chicago Police Department had already determined that he was disabled and would not assign him a position within the department.
This interpretation created tension between the police department's determination of an officer's fitness for duty and the retirement board's independent assessment for benefit eligibility. The appellate court essentially held that when the police department itself concludes an officer is too disabled to work in any capacity, the retirement board cannot subsequently deny disability benefits.
The retirement board challenged this interpretation by petitioning for leave to appeal to the Illinois Supreme Court under Rule 315(a). The high court granted the petition, indicating the case presents issues of sufficient legal significance to warrant review.
According to court documents, the retirement board argues that Moreland's disability claim was properly denied because he did not provide adequate proof of disability to the board. This suggests the central legal question involves the standard of evidence required for disability benefits and whether a police department's internal determination of unfitness for duty constitutes sufficient proof for pension purposes.
The case highlights broader questions about the relationship between police departments and their pension systems. Police officers typically must meet specific criteria to qualify for duty disability benefits, which provide financial support for officers who become unable to perform their duties due to injuries or illnesses sustained in the line of duty. These benefits often provide more generous compensation than regular retirement benefits and may be available to officers regardless of their length of service.
The retirement board's position appears to emphasize the independence of pension benefit determinations from departmental personnel decisions. The board may argue that its role requires independent medical and legal review, even when a police department has already concluded an officer cannot continue working.
Conversely, Moreland's position, as supported by the appellate court, suggests that when a police department determines an officer is unfit for any assignment due to disability, this determination should carry significant weight in pension benefit decisions. This interpretation could streamline the disability benefit process for officers who have already been deemed unfit by their departments.
The Illinois Supreme Court's decision in this case could establish new precedent for how police disability benefits are evaluated statewide. A ruling favoring the retirement board might strengthen pension boards' authority to conduct independent disability determinations, while a decision supporting Moreland could create a more officer-friendly standard when police departments have already concluded an officer is disabled.
Justice Rochford delivered the court's judgment with opinion, joined by Chief Justice Neville and Justices Theis, Overstreet, Holder White, Cunningham, and O'Brien. The unanimous nature of the court's participation suggests the justices recognized the case's importance for police pension law in Illinois.
The opinion was filed November 20, 2025, though the full text of the court's reasoning and holding was not immediately available. The case will likely be closely watched by police officers, pension administrators, and municipal officials throughout Illinois, as it could affect how disability benefit claims are processed for law enforcement personnel across the state.
The outcome will determine whether police departments' fitness-for-duty determinations create a presumption in favor of disability benefits or whether pension boards retain full authority to make independent benefit determinations regardless of departmental decisions.