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October 15, 2025

Group of Parents File Suit Against 145 School Districts; the ISBE, and Governor Pritzker –

By John Kraft & Kirk Allen

On October 20, 2021

Carlinville, IL. (ECWd) –

A large group of parents from across the state have filed an 11-Count Amended Complaint in Carlinville, naming 145 School Districts, the Illinois State Board of Education, Dr. Ngozi Ezike, and Governor Pritzker as Defendants.

This was filed in Macoupin County, where the original Plaintiff filed it.

The Complaint is (HERE) or below for your reading pleasure.

List of the 11 Counts from the Complaint – each count is applicable to all Defendants and from all Plaintiffs (even though the text is for a specific school district:

  • DECLARATORY JUDGMENT –
    • Declaring the local health department, and not the School District, is vested with the
      responsibility of determining if NMCUSD#34 Parents’ minor child T.M., and all children, as
      Students who are similarly situated, are or have been in “close contact”;
    • Declaring the local health department, and not the School District, is vested with the authority
      to isolate or quarantine NMCUSD#34 Parents’ minor child T.M., and all children, as Students
      who are similarly situated, due to such Student having been determined to have been in “close
      contact”;
    • Declaring the District must have an order of quarantine from the local health department before
      T.M, and all children, as Students who are similarly situated, before any of Student can be
      excluded from the District facilities, relegated to remote learning, and be denied in-person
      learning.
  • REQUEST FOR INJUNCTION
    • Under the facts presented herein, and pursuant to prior orders of this Court in related matters,
      full in-person learning on the premises of NMCUSD#34 for T.M., and all children and Students
      similarly situated, is compulsory absent an order of quarantine having issued against a child or
      Student by the county health department or IDPH.
    • Absent a quarantine order having issued from the county health department or IDPH,
      NMCUSD#34, and/or Defendant Goble, are not lawfully authorized to suspend the in-person
      learning on the premises of NMCUSD#34 of T.M., and all children and Students similarly
      situated, for allegedly being in close contact to a positive COVID person.
    • NMCUSD#34, and/or Defendant Goble, or any agent acting on their behalf, unless a valid and
      order of quarantine has been properly issued on behalf of the county health department or the
      Illinois Department of Health, are permanently enjoined from quarantining T.M., and all
      children or Students similarly situated, and are further permanently enjoined from disallowing
      the entry of such children or Students into the facilities of NMCUSD#34 to receive their in person
      education.
  • THE SCHOOL DISTRICTS CANNOT LAWFULLY EXCLUDE A STUDENT AS AN ALLEGED CLOSE CONTACT WITHOUT PARENTAL CONSENT OR A LAWFUL ORDER OF QUARANTINE
  • DECLARATORY JUDGMENT THE SCHOOL DISTRICTS CANNOT LAWFULLY EXCLUDE A STUDENT AS AN ALLEGED CLOSE CONTACT WITHOUT PARENTAL CONSENT OR A LAWFUL ORDER OF MODIFIED QUARANTINE
  • DECLARATORY JUDGMENT THE DISTRICTS CANNOT REQUIRE MASKS AS A TYPE OF TREATMENT WITHOUT CONSENT OR A LAWFUL ORDER OF QUARANTINE
  • DECLARATORY JUDGMENT THE DISTRICTS CANNOT REQUIRE MASKS AS TYPE OF MODIFED QUARANTINE TO LIMIT THE SPREAD OF AN INFECTIOUS DISEASE WITHOUT CONSENT OR A LAWFUL ORDER OF QUARANTINE
  • DECLARATORY JUDGMENT IDPH EMERGENCY RULE IS NOT LAWFUL AUTHORITY FOR WHICH THE SCHOOL DISTRICTS CAN BASE THEIR MASK AND EXCLUSION POLICIES
  • DECLARATORY JUDGMENT ISBE GUIDANCE IS NOT LAWFUL AUTHORITY FOR WHICH THE SCHOOL DISTRICTS CAN BASE THEIR MASK AND EXCLUSION POLICIES
  • DECLARATORY JUDGMENT EXECUTIVE ORDERS OF PRITZKER REGARDING MASKING AND EXCLUSION OF STUDENTS ARE ULTRA VIRES
  • REQUEST FOR AN INJUNCTION ENJOINING MASKS BEING COMPELLED BY SCHOOL DISTRICTS
  • REQUEST FOR AN INJUNCTION ENJOINING EXCLUSION FROM SCHOOL BY SCHOOL DISTRICTS
Complaint for Declaratory Judgment & Injunctive Relief FINAL

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