Clark Co. (ECWd) –
(35 ILCS 200/18-15) Sec. 18-15. Filing of levies of taxing districts. (a) Notwithstanding any other law to the contrary, all taxing districts, other than a school district subject to the authority of a Financial Oversight Panel pursuant to Article 1H of the School Code, and except as provided in Section 18-17, shall annually certify to the county clerk, on or before the last Tuesday in December, the several amounts that they have levied.
The Clark County Park District, commonly known as Mill Creek, failed to certify to the county clerk an adopted tax levy before the last Tuesday in December of 2025.
What does such a failure mean if the law is followed?
It means the Park District failed to submit a tax levy, and there should not be any tax levied for them during the next tax cycle because of that failure.
Where this gets interesting is going to be how upcoming attempts are made to correct this failure. We note that we have not found a single provision to correct a failure to file. There are provisions to amend a levy properly and timely filed. Such provisions, based on statutory construction, indicate that had the legislature wanted public bodies to have an amendment process for a failure to file by a specific deadline, they would have included one. The fact they did not include such a provision creates a statutory prohibition.
The Park District has a resolution for a tax levy that they intend to vote on at their January 15, 2026, meeting.
Any such adoption does nothing for them if the law is followed because of the failure to submit the levy to the County Clerk by the established deadline.
“Earlier decisions of this court have rather clearly established that, with certain exceptions not applicable here, an additional levy or an amended levy, adopted subsequent to the last Tuesday in September, is of no effect unless its purpose is to correct errors in an earlier certificate which did not accurately reflect the action of the boards. (“Board of Education v. Barrett”)
A copy of the proposed resolution can be downloaded at this link or viewed below.
2025-2026 Annual Levy Ordinance




One Response
The park district has moved the meeting up according to a post on their website.