Pisano v. Giordano

Can either the trial court or a reviewing court re-examine an administrative agency’s actions without a record before it?

No.

No court — trial or appellate — can function in a vacuum.

Administrative review presupposes a record of the proceedings before the agency.

Following a decision by the Director of the Illinois Department of Personnel — which resulted in reduced health care benefits to State employees, annuitants, and, where elected, qualified dependents — the plaintiffs brought suit for administrative review. Named as defendants in the suit were the Director, numerous other State officials…