In Davis v. Village of Maywood, 2020 IL App (1st) 191011, the First District of the Illinois Appellate Court held that a party demonstrated good cause to justify a late filing based on his attorney's "minor, understandable" e-filing error.
Plaintiff's counsel attempted to e-file a complaint on the morning of the day the statute of limitations was set to expire. When submitting the complaint, he entered his Cook County Attorney Code in the "Lead Attorney" field but did not reenter it in the field labeled "Case Cross Reference Number." Four days later, the circuit court clerk reviewed the submission and rejected it because counsel did not reenter his Cook County Attorney Code. Counsel resubmitted the same complaint with the Code later that day, and it was accepted. The circuit court later dismissed the complaint as untimely.
The First District reversed, holding that plaintiff established good cause for the late filing under Illinois Supreme Court Rule 9(d)(2), which states that a party may "seek appropriate relief from the court, upon good cause shown" if an e-filed document "is rejected by the clerk and is therefore untimely." The court emphasized that the complaint itself was substantively correct, that the e-filing submission contained all of the other necessary information, and that it was "neither . . . obvious nor intuitive" that counsel should have reentered his Attorney Code in the "Case Cross Reference Number" field. The court also noted that the e-filing platform and Cook County circuit court clerk subsequently warned users about this very problem, showing that the field's label was unclear. Because the name of that field was "confusing at best and misleading at worst," it contributed to counsel's error and constituted good cause.
The First District's opinion may be found here.