Illinois School District
Legal Services Accountability Report

REQUEST FOR REVIEW — PUBLIC ACCESS COUNSELOR

North Chicago Community Unit School District #187 — Untimely FOIA Response

Date: May 15, 2026

I. Identification of Public Body

North Chicago Community Unit School District #187, 2000 Lewis Avenue, North Chicago, Illinois 60064. Superintendent: Dr. John P. Price, Ed.D. (jprice@d187.org, 847-775-1140).

II. Description of FOIA Request

On April 13, 2026 at 7:38 PM, the undersigned submitted a FOIA request to North Chicago CUSD 187 via email requesting: (1) names of law firms providing legal services; (2) engagement agreements with counsel; and (3) total amounts paid to each law firm for the past three fiscal years.

III. Nature of the Violation

Under 5 ILCS 140/3(d), a public body must respond to a FOIA request within five (5) business days of receipt. With proper written notice citing good cause, the response period may be extended by no more than five (5) additional business days — but only if the written notice is provided within the original five-day window.

The District did not respond within five business days (deadline: approximately April 18, 2026). No written extension notice was provided within the statutory window. The District's final response was transmitted on May 8, 2026 — approximately eighteen (18) business days after receipt of the request.

IV. Documentary Evidence

The District's response email (May 8, 2026) contains the following admission:

"I apologize for the delayed response on this FOIA request that was received on April 20, 2026."

The internal email chain attached to the District's response shows Superintendent Price forwarded the original request on April 20, 2026 with the note:

"not sure I sent this to you — sorry!"

This constitutes direct documentary evidence that: (a) the District received the request no later than April 14, 2026; (b) the Superintendent failed to route it to the FOIA Officer for seven days; and (c) no extension notice was ever provided.

V. Relief Requested

The undersigned respectfully requests that the Public Access Counselor: (1) find that North Chicago CUSD 187 violated 5 ILCS 140/3(d); (2) direct the District to designate and publish a FOIA Officer contact pursuant to 5 ILCS 140/3.5; and (3) issue a binding opinion that the District's response procedures are inadequate.

Respectfully submitted,

______________________________
Michael F. Henry
Illinois Resident
708-446-4416 | michaelfhenry@live.com

GOVERNANCE COMPLAINT — ILLINOIS STATE BOARD OF EDUCATION

Prairie Hill SD 133 & Wood Dale SD 7 — Attorneys Paid Without Engagement Agreements

Date: May 15, 2026

I. Nature of Complaint

This complaint is submitted pursuant to the Illinois State Board of Education's authority to receive and investigate reports of financial irregularities and governance failures in Illinois public school districts under 105 ILCS 5/2-3.25g and related provisions.

II. Prairie Hill School District #133 (RCDT: 04-101-1330-04)

In response to a FOIA request for engagement agreements with legal counsel, Prairie Hill SD 133 stated: "As to Request #2, no responsive records exist." The district simultaneously identified law firms providing legal services and directed the requestor to its Annual Statement of Affairs — which reflects payments to attorneys.

A school district paying attorneys without a written engagement agreement potentially violates 105 ILCS 5/10-20.21, which requires board authorization for all contracts. Without written engagement agreements, there is no documentation that: (a) the board specifically authorized the firm; (b) hourly rates were board-approved; (c) the scope of representation was defined; or (d) conflict-of-interest disclosures were made.

III. Wood Dale School District 7 (DuPage County)

Wood Dale SD 7 explicitly stated: "No current engagement agreements or contracts." The district disclosed three law firms used over eight years (Himes, Petrarca & Fester; Robbins Schwartz; Hodges Loizzi) and provided an invoice listing. Three major Illinois school law firms were retained and compensated over eight years with no written contractual basis.

This represents a systematic failure of the board's fiduciary duty and potentially constitutes ultra vires expenditure under 105 ILCS 5/10-20.21 for every invoice paid without board authorization of the specific rate, scope, and terms.

IV. Relief Requested

The undersigned respectfully requests that ISBE: (1) direct the Regional Office of Education to conduct a governance review of Prairie Hill SD 133 and Wood Dale SD 7; (2) require both districts to produce board minutes reflecting the authorization of legal counsel for the past eight years; (3) if no such minutes exist, refer to the Illinois Comptroller for audit of unauthorized expenditures; and (4) require both districts to adopt written engagement agreement policies.

Respectfully submitted,

______________________________
Michael F. Henry
Illinois Resident
708-446-4416 | michaelfhenry@live.com

PROFESSIONAL CONDUCT INQUIRY — ATTORNEY REGISTRATION & DISCIPLINARY COMMISSION

Del Galdo Law Group — Unilateral Fee Increases Without Client Board Approval

Date: May 15, 2026

I. Nature of Inquiry

This inquiry is submitted regarding Del Galdo Law Group's practice of issuing unilateral fee increase notifications to school district administrative staff, bypassing the school board — the actual client and governing body of the public school district.

II. Factual Basis

In response to FOIA requests, two school districts produced documents titled "Del Galdo Law Group — [District Name] Notification of Client Increase." These letters notify district administrators of increased hourly rates, without any documentation that the rate increase was:

(a) communicated directly to the board of education (the client body);
(b) approved by the board in open session as required by 105 ILCS 5/10-20.21;
(c) acknowledged in a written fee agreement amendment signed by a board-authorized representative.

The districts are: (1) Berwyn South School District 100, Cook County; (2) Chicago Heights School District 170, Cook County.

III. Applicable Professional Rules

Illinois Rules of Professional Conduct, Rule 1.5(b): "When the lawyer has not regularly represented the client, the basis or rate of the fee and expenses for which the client will be responsible shall be communicated to the client, in writing, before or within a reasonable time after commencing the representation." A change in fee rate constitutes a material change in the fee basis and must be communicated to the client — the board of education — not merely to administrative staff.

ILRPC Rule 1.4(b): "A lawyer shall explain a matter to the extent reasonably necessary to permit the client to make informed decisions regarding the representation." A board of education cannot make an informed decision about a rate increase it was never notified of.

IV. Relief Requested

The ARDC is respectfully requested to: (1) investigate Del Galdo Law Group's fee increase notification practices; (2) determine whether these notifications were communicated to school boards rather than administrators only; and (3) if violations are found, take appropriate disciplinary action.

Respectfully submitted,

______________________________
Michael F. Henry
Illinois Resident
708-446-4416 | michaelfhenry@live.com