Giovenco v. BOARD OF FIRE & POLICE COM'RS OF VILLAGE OF RIVER GROVE

In Carver v. Nall, 186 Ill. 2d 554, 561-62, 714 N.E.2d 486 (1999), our supreme court held that a final order of a unit of local government need not include notice to its recipients of the right to administrative review. We now must determine whether Carver applies retroactively. We hold that it does.

In April 1998 Joseph Giovenco applied to the Village of River Grove Board of Fire and Police Commissioners for a position as a police officer. The board notified him, by letter dated April 27, 1998, that it rejected his application. The letter did not mention the right to administrative review.

Giov…