Dardeen v. Heartland Manor, Inc.

At issue in this appeal is whether an amendment to section 3 — 602 of the Nursing Home Care Act (Act) (210 ILCS 45/3 — 602 (West 1996)) should be given retroactive effect. Prior to the amendment, section 3 — 602 required a licensee to pay treble damages plus costs and attorney fees to a facility resident for a violation of the resident’s . rights under article II, part 1, of the Act (see 210 ILCS 45/2 — 101 et seq. (West 1994)). Public Act 89 — 197 (Pub. Act 89 — 197, § 90, eff. July 21, 1995) repealed the treble damages provision contained in section 3 — 602, limiting recovery for violations…