Stay of Enforcement Request - Illinois
Motion for Limited Stay of Agency Enforcement Pending Administrative Review
IN THE CIRCUIT COURT OF [COUNTY] COUNTY, ILLINOIS
| Party | Role |
|---|---|
| [PLAINTIFF NAME] | Plaintiff |
| v. | Case No. [NUMBER] |
| [AGENCY NAME] | Defendant |
| [OTHER REQUIRED DEFENDANTS] | Additional defendants |
Motion for Limited Stay of Enforcement
Plaintiff [NAME] moves under 735 ILCS 5/3-111(a)(1) for a stay limited to [IDENTIFY PRECISE ENFORCEMENT ACTIONS] while this administrative review action is pending. In support, plaintiff states:
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The agency's final decision dated [__/__/____], served on [__/__/____], orders [EXACT OBLIGATIONS OR SANCTIONS]. The order is attached as Exhibit A. It [STATES WHETHER IT IS FINAL AND SUBJECT TO THE ADMINISTRATIVE REVIEW LAW].
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The agency's governing act expressly adopts the Administrative Review Law at [ENABLING ACT AND SECTION]. Plaintiff filed the complaint for administrative review on [__/__/____], and summons issued on [__/__/____], within the applicable 35-day period after service of the decision under 735 ILCS 5/3-103. This action remains pending.
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Plaintiff requests a stay of only [SPECIFY PROVISION, PAYMENT, CLOSURE, SUSPENSION, OR OTHER ENFORCEMENT STEP]. The agency may continue [IDENTIFY ANY UNAFFECTED REQUIREMENTS]. The requested stay would end on [FINAL DISPOSITION / EARLIER DATE REQUESTED].
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Plaintiff gave the agency notice of this motion on [__/__/____] by [METHOD] to [RECIPIENT]. Notice to all other parties was given on [__/__/____] by [METHOD]. The proof of notice is attached as Exhibit B.
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Status quo and public safety. Immediate relief is needed because [SPECIFIC EVENT, DATE, AND HARM THAT WOULD OCCUR BEFORE REVIEW]. Staying the identified enforcement step would preserve [DESCRIBE CURRENT CONDITION] without endangering the public because [CONCRETE SAFEGUARDS, CONTINUING CONDITIONS, OR EVIDENCE].
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Public policy. The requested limited stay is consistent with public policy because [EXPLAIN THE PUBLIC INTEREST AND WHY THE LIMITED PAUSE DOES NOT UNDERMINE THE REGULATORY PURPOSE].
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Likelihood of success. Plaintiff has a reasonable likelihood of success on the merits because [IDENTIFY SPECIFIC ERROR, RECORD SUPPORT, AND GOVERNING AUTHORITY]. The complaint alleges [POINT TO THE CLAIM AND RECORD MATERIAL].
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The statute governing the agency decision [DOES / DOES NOT] impose a different stay or bond rule: [CITATION AND EFFECT]. Plaintiff requests [NO BOND / BOND OF $AMOUNT / THE SECURITY REQUIRED BY THAT ACT] because [FACTS AND AUTHORITY].
WHEREFORE, plaintiff asks the Court, after notice and a finding of good cause, to stay [PRECISE ENFORCEMENT ACTION] until [END EVENT], subject to [PROPOSED CONDITIONS], and grant other relief authorized by law.
Respectfully submitted,
Signature: [________________________________]
Name: [________________________________]
Attorney ARDC number, if applicable: [________________________________]
Address: [________________________________]
Telephone and email: [________________________________]
Date: [__/__/____]
Certificate of notice
I certify that on [__/__/____] I sent this motion and its exhibits to [AGENCY COUNSEL AND OTHER COUNSEL OR PARTIES] by [METHOD] at [ADDRESS OR EMAIL].
Signature: [________________________________]
About this template
- Last updated
- September 27, 2026
- Citations checked
- September 27, 2026
- Jurisdiction
- Illinois
- Category
- Administrative Law
Legal authority
- 735 ILCS 5/3-102
- 735 ILCS 5/3-103
- 735 ILCS 5/3-111(a)(1)
- 5 ILCS 100/10-50(b)
Administrative law covers how you interact with government agencies, from filing a comment on a proposed rule to appealing a denied license or benefit. Agency processes have their own forms, deadlines, and evidence standards that are different from what courts use. Getting the paperwork wrong usually means missing a deadline or losing the right to appeal, so precision in these documents matters as much as it does in a courtroom filing.
Not legal advice
This template is provided for informational purposes. We recommend having an attorney review any legal document before signing, especially for high-value or complex matters.
Checked against the law it cites
A reviewer verified this template's legal citations against the official source on September 27, 2026.
5 ILCS 100/10-50(b) (checked September 27, 2026): "All agency orders shall specify whether they are final and subject to the Administrative Review Law."
735 ILCS 5/3-111(a)(1) (checked September 27, 2026): "For the purpose of this subsection, "good cause" requires the applicant to show (i) that an immediate stay is required in order to preserve the status quo without endangering the public, (ii) that it is not contrary to public policy, and (iii) that there exists a reasonable likelihood of success on the merits;"
735 ILCS 5/3-102 (checked September 27, 2026): "This Article III shall apply to and govern every action to review judicially a final decision of any administrative agency where the Act creating or conferring power on such agency, by express reference, adopts the provisions of this Article III or its predecessor, the Administrative Review Act."
735 ILCS 5/3-103 (checked September 27, 2026): "Every action to review a final administrative decision shall be commenced by the filing of a complaint and the issuance of summons within 35 days after the date that a copy of the decision sought to be reviewed was served upon the party affected by the decision"
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