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CIRCUIT COURT OF
COOK COUNTY, ILLINOIS
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
LAW DIVISION
COUNTY DEPARTMENT, LAW DIVISION CLERK DOROTHY BROWN
TAX & MISCELLANEOUS REMEDIES SECTION

ILLINOIS RETAIL MERCHANTS )

ASSOCIATION; BERKOT, LTD. d/b/a )
BERKOT SUPER FOODS; FAIRPLAY, INC. )
d/b/a FAIRPLAY FOODS; )
CHIQUITA FOOD MARKET, INC. d/b/a )
FOOD MARKET LA CHIQUITA & TAQUERIA; ) Case No. 2017 L 050596
LEAMINGTON FOODS, INC.; TONYS )
FINER FOODS ENTERPRISES, INC. d/b/a )
TONYS FRESH MARKET; )
VALLI PRODUCE, INC.; and WALTS )
LAGESTEE, INC. d/b/a )
WALTS FOOD CENTERS, )
)
)
Plaintiffs, )
)
v. )
)
THE COOK COUNTY DEPARTMENT OF )
REVENUE; ZAHRA ALI, as Director of )
the Cook County Department of Revenue; )
and the COUNTY OF COOK , )
)
Defendants. )

PLAINTIFFS RESPONSE IN OPPOSITION TO

DEFENDANTS MOTION TO DISMISS

Plaintiffs, Illinois Retail Merchants Association, et al. (collectively, Plaintiffs), by their

attorneys, Horwood Marcus & Berk Chartered, in opposition to Defendants Section 2-615

Motion to Dismiss Plaintiffs Verified Complaint (the Motion), submit this Memorandum in

support thereof, and state as follows:

I. FACTUAL BACKGROUND

Cook County adopted the Sweetened Beverage Tax under Cook County Ordinance No.

16-5931 (the Ordinance). The Ordinance is effective March 1, 2017 and levies the tax

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 beginning on July 1, 2017. The tax is levied at a rate of $0.01 per ounce on the retail sale of all

sweetened beverages in Cook County.

On June 27, 2017, Plaintiffs filed a Verified Complaint (the Complaint) seeking a

Declaratory Judgment that the newly enacted Sweetened Beverage Tax (the Tax) violates the

Illinois Constitution. This Court issued a temporary restraining order on June 30, 2017, enjoining

Defendants from imposing the Tax, which was affirmed by the Illinois Appellate Court on July

10, 2017. The Tax remains subject to the restraining order while this Motion is considered.

II. MOTION TO DISMISS STANDARD

A section 2-615 motion tests only the legal sufficiency of a pleading. Rajterowski v. City

of Sycamore, 405 Ill. App. 3d 1086, 1092 (2nd Dist. 2010); DeWoskin v. Lowes Chicago
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Cinema, 306 Ill. App. 3d 504, 523 (1st Dist. 1999). The motion cannot raise affirmative factual
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defenses. Id. All well-pleaded facts must be accepted as true and all reasonable inferences

therefrom must also be accepted as true. Id. Furthermore, the allegations in the pleading must

be construed in the light most favorable to the plaintiff. Id. A plaintiff is not required to prove

his or her case at the pleading stage. Id. With respect to a motion to dismiss a complaint under

section 2-615, the question is whether sufficient facts are contained in the pleadings which, if

established, could entitle the plaintiff to relief. Kanerva v. Weems, 2014 IL 115811, 33 (2014).

A cause of action should not be dismissed unless it is clearly apparent from the pleadings that

no set of facts can be proven that would entitle the plaintiff to recover. Id.

III. LAW AND ARGUMENT

Plaintiffs Complaint has clearly and sufficiently set forth the law and factual basis that,

if proven, entitle Plaintiffs to relief. Specifically, the Complaint clearly alleges that the Tax is in

violation of the Uniformity Clause of Article IX, Section 2 of the Illinois Constitution, as it fails

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 to tax sugary beverages uniformly. The Complaint also properly alleges that the Tax is

unconstitutionally vague in that compliance is impossible, as well as the fact that the Tax

contains internal inconsistencies and improperly conflicts with other laws. In spite of these

allegations, Defendants are attempting to litigate the merits of this case through the Motion by

introducing factual evidence outside of the Complaint and legal arguments properly suited for

other proceedings. The Complaint, contrary to Defendants assertions, at the minimum meets the

requirements of pleading and this matter should be allowed to proceed.

It should be noted that in challenging the Complaint, Defendants dedicate nearly three

pages of their Motion arguing that Cook County, as a home rule unit, has the power to tax, that

the Ordinance pertains to the government and affairs of the County and that the Ordinance is
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not pre-empted by state law. Although Plaintiffs do not stipulate to the correctness of
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Defendants position, Defendants arguments are irrelevant because Plaintiffs have not made any

such challenges. Similarly, Defendants constant references to other taxes imposed by

Defendants that are structured similarly are also irrelevant because it is the Sweetened Beverage

Tax and its classifications and language that are being challenged. For the reasons discussed

herein, the Complaint sufficiently and fully alleges claims that entitle Plaintiffs to relief.

A. The Sweetened Beverage Tax Violates the Uniformity Clause

Article IX, Section 2 of the Illinois Constitution sets forth limitations on classifications,

exemptions, deductions, allowances and credits of non-property taxes. Specifically, that section,

the uniformity clause, provides:

In any law classifying the subjects or objects of non-property taxes

or fees, the classes shall be reasonable and the subjects and objects
within each class shall be taxed uniformly. Exemptions,
deductions, credits, refunds and other allowances shall be
reasonable.

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 Id. The uniformity clause places even greater limitations on Illinois state and local governments

than the equal protection clauses of the constitutions of Illinois (Art. 1, 2) and United States

(Fourteenth Amendment, 1). See Arangold Corp. v. Zehnder, 204 Ill. 2d 142, 152 (2003);

Searle Pharmaceuticals, Inc. v. Dept of Rev., 117 Ill. 2d 454, 467 (1987). The classification of

a non-property tax must be based on a real and substantial difference between those taxed and

those not taxed, and must bear some reasonable relationship to the object of the legislation or to

public policy. Gejas Caf v. Metro. Pier & Exposition Auth., 153 Ill. 2d 239, 245 (1992). In

addition, [d]ecisions have held the constitutional mandate of uniformity to have been violated

where the ordinance included within a class those in fact not within it or excluded those properly

belonging to it. North Sheffield, Inc. v. Chicago, 144 Ill. App. 3d 913, 916-18 (1st Dist. 1986).
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In evaluating a uniformity challenge in the context of a section 2-615 motion to dismiss,

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the standard required by a party to challenge a tax must be considered in whether a pleading

sufficiently states a cause of action upon which relief can be granted. Specifically, in order to

challenge a tax under the uniformity clause, the party challenging the tax must make a good faith

argument that the classifications created by the tax are not uniform. Gejas Caf, 153 Ill. 2d at

248. After the challenger has made a good faith argument that the classifications have no real

and substantial difference, the burden of proof shifts to the taxing entity to provide a justification

for the classifications. Id. Only when the taxing entity has provided its justification does the

burden shift back to the challenger to prove that the justifications are not based in fact or law. Id.

Plaintiffs Complaint details the legal basis (Complaint at 35) and pleads sufficient facts

(Complaint at 36 43), that the Sweetened Beverage Tax violates the uniformity clause and

thus, is sufficient to establish a good faith argument to state a basis upon which relief can be

granted.

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 Although Defendants misstate the test for a uniformity challenge by omitting the initial

burden of a party challenging a tax to make a good faith argument, Defendants do acknowledge

their subsequent burden and offer up various factual arguments in their attempt to show that the

differences between the taxed and un-taxed sweetened beverages are real and substantial. (D.

Motion at pp. 7-11). Among the factual justifications for the difference raised by Defendants

are: (1) pre-made drinks and custom-made drinks are never the same product; (2) pre-packaged

items are made in different locations, with different ingredients and have been sitting in its

container for a period of time, and (3) pre-made sweetened beverages are far more readily

available for purchase and consumption than not-ready-to-drink beverages. (D. Motion at pp. 7-

9). It is important to note that none of these facts can be considered in a section 2-615 motion to
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dismiss. Indeed, a section 2-615 motion is an inappropriate vehicle to be used in attacking the
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plaintiffs complaint . . . if a taxing body is required to rely on factual matters outside of the

complaint to establish a justification for a tax classification. DeWoskin, 306 Ill. App. 3d at 523;

see also Friedman v. White, 2015 Ill. App. (2d) 140942, 11 (2nd Dist. 2015). Defendants

factual allegations are entirely outside of the Complaint and cannot be considered.

The Complaint provides sufficient factual pleadings to make a good faith uniformity

challenge and withstand a section 2-615 motion to dismiss. As plead in the Complaint, Cook

County created non-uniform classifications in the Tax in violation of the uniformity clause. See

Complaint at 34-45. Specifically, under the Tax, ready-to-drink, pre-made sweetened

beverages (e.g., sweetened iced tea served in a bottle or from a chilled beverage dispensing

machine) are taxable, but on-demand, custom sweetened beverages (e.g., sweetened iced tea

mixed by a server or barista) are not subject to the Tax. See Complaint at 36. The sweetened

beverages in both classifications are substantially similar, if not identical. See Complaint at 37.

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 Consequently, Plaintiffs have met their burden to make a good faith argument and allege

sufficient facts upon which relief can be granted.

Furthermore, although Plaintiffs have met the burden to make a good faith argument that

the Tax violates the uniformity clause, Plaintiffs also alleged facts in the Complaint that even if

the classifications were real and substantial, the Tax fails to satisfy the minimum standards of the

uniformity clause because the classifications are not reasonably related to the purpose of the law.

See Complaint at 38. Despite the stated justification to promote public health and reduced

obesity rates in the Ordinance, the express purpose is not consistent with the classification drawn

by Defendants because it generally excludes sweetened beverages that are not ready-to-drink. 1

See Complaint at 36. But, there is no difference in health consequences from a ready-to-drink,
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pre-made sweetened beverage from a sweetened beverage made on-demand. See Complaint at
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38. Because the beverages are substantially similar, if not identical, the Sweetened Beverages

Tax violates the uniformity clause. See Complaint at 39. The Complaint has clearly met the

minimum standard to sufficiently plead Plaintiffs case and the Motion should be denied.

Finally, Defendants cling to American Beverage Association v. City of Chicago, 404 Ill.

App. 3d 682 (1st Dist. 2010), which held that there were real and substantial differences between

bottled noncarbonated water and other types of bottled beverages that contain flavoring,

vitamins, caffeine, nutritional additives or carbonation. Id. at 691. Not only do Defendants fail

to give any basis for such comparison, other than conclusory statements that the difference of

taxable and non-taxable sweetened beverages is real and substantial, but American Beverage

Association does not support Defendants position. Unlike the bottled water and other beverages

1
Defendants counsel openly admits the real purpose of the tax to raise revenue. (D. Motion at p. 10).
Additionally, Defendants admit that the exclusion of customization is really a collection issue and cuts into
Defendants anticipated revenue. (D. Motion at p. 8).

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 in American Beverage Association, the classifications in this matter involve substantially similar,

if not identical sweetened beverages; for example, sweetened iced tea in an urn as compared to

sweetened iced tea for an individual order. Consequently, Defendants reliance on American

Beverage Association is misplaced.

Instead, the holdings by the First Judicial District in North Sheffield, Inc. v. Chicago, 144

Ill. App. 3d 913 (1st Dist. 1986) and Satellink of Chicago, Inc. v. Chicago, 168 Ill. App. 3d 689

(1st Dist. 1988), are directly on point because the court in each case held that the uniformity

clause was violated where beverages and cable television, respectively, were classified and taxed

in non-uniform classifications. The fact that the purpose of those taxes were not to discourage

behavior is of no consequence 2 the proper analysis is whether the law creates classifications
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that have no real and substantial difference, just like the sweetened beverages in this matter.
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Similarly, Defendants arguments focusing on whether a beverage is ready-made has no

impact whether the sweetened beverages taxed and not-taxed have a real and substantial

difference. 3

As demonstrated above and as clearly apparent from the face of the Complaint, Plaintiffs

have sufficiently pled facts to meet their burden to establish a good faith uniformity challenge.

See Terry v. Metro. Pier & Expo. Auth., 271 Ill. App. 3d 446, 450 (1st Dist. 1995). Defendants

attempt to have the merits of the uniformity challenge decided in this Motion is improper.

Similarly, Defendants factual arguments are simply not appropriate at this stage in the

2
Defendants argument even suggests that where the purpose of a tax is to discourage certain behavior, the tax
cannot violate the uniformity clause, but, if such an argument were true the uniformity clause would be meaningless.
3
It also bears noting that the Tax has absolutely no relationship to the amount of sweetener or artificial sweetener in
a beverage. Even a minimal amount of sweetener or artificial sweetener, even no calorie sweetener, will cause a
beverage to be taxable. Thus, the argument that a ready-made sweetened beverage will be consistent is irrelevant.

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 proceedings. The Complaint plainly meets the minimum requirements to allege a factual and

legal basis for a uniformity challenge to the Tax. Defendants Motion should be denied.

B. The Sweetened Beverage Tax is Invalid because it is Impossible to Implement

With Any Precision

The Sweetened Beverage Tax is also invalid because the administrative burden on

retailers of sweetened beverages is so substantial due to the vagueness of the Ordinance, which

has been amplified by the hastily issued regulations, lack of guidance, reversal of positions and

potential for liability. Indeed, a law must meet certain minimum standards such that those it

affects are able to comply:

A law must be complete in all its terms and conditions when it

leaves the legislature, so that every person may know, by reading
the law, what his rights are and how it will operate when put into
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execution. While it is the duty of the courts to ascertain the

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meaning of and to give effect to every valid act of the legislature,

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yet they cannot supply omissions or remedy defects in matters

committed to the legislature. A legislative act which is so vague,
indefinite and uncertain that the courts are unable, by accepted
rules of construction, to determine, with any reasonable degree of
certainty, what the legislature intended, or which is so incomplete
or conflicting and inconsistent in its provisions that it cannot be
executed, will be declared to be inoperative and void. An act is
void the language of which appears, on its face, to have a meaning
but to which it is impossible to give any precise or intelligible
application in the circumstances under which it is intended to
operate.

Spinelli v. Immanuel Lutheran Evangelical Congregation, Inc., 515 N.E.2d 1222, 1228 (Ill.

1987) (internal citations omitted). Consequently, while an act is not required to be

mathematically certain in its language, it must meet minimum standards in order to be

enforced. People v. Boclair, 789 N.E.2d 734, 743 (Ill. 2002). As sufficiently alleged in the

Complaint, the Ordinance fails to meet even these minimum standards. 4

4
Defendants Motion states: [T]here is a great[] tolerance for vagueness in civil ordinances. (D. Motion at p.
13). This statement is misleading and taken out of context by Defendants. The actual language is: We have

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 As alleged in the Complaint, the Ordinance is so vague that it is impossible for any

distributor or retailer to be precise or intelligible in the application of the tax in the

circumstances under which it is intended to operate. Spinelli, 515 N.E.2d at 1228; see

Complaint at 48. Under the plain language of the Ordinance, retailers cannot comply with any

precision. The imposition provision is merely: Effective July 1, 2017, a tax at the rate of $0.01

per ounce is hereby imposed on the retail sale of all sweetened beverages in Cook County.

Section 74-852(a). Applying this tax to a sweetened beverage not served in sealed containers is

simply impractical and impossible. See, e.g., Complaint at 57. The issues raised by Plaintiffs

are not some hypotheticals conjured up to challenge the Tax; rather, these circumstances are

certain, inescapable outcomes under the plain application of the Tax. Defendants assertions to
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the contrary are false.

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In defending the imposition provision, Defendants merely recite that the tax is imposed

on the amount of ounces sold. Defendants further contend that such statement, as supplemented

by the regulations, 5 leads to the conclusion that the Ordinance sets forth clearly perceived

boundaries. (D. Motion at p 14). But it is the language of the Ordinance itself that is vague, as

alleged in the Complaint. See Complaint at 48. Defendants have offered nothing nor could

they in a section 2-615 motion to dismiss that contradicts the facts as alleged in the Complaint,

and which must be accepted as true for purposes of this proceeding.

typically shown greater tolerance for vagueness in civil, rather than criminal statutes. In re Omar M., 2012 IL App.
(1st) 100866, 81 (1st Dist. 2012). The Illinois Supreme Court has explained this different tolerance because
criminal penalties are more severe. Wilson v. County of Cook, 2012 IL 112026, 23 (2012). Ironically, the
Ordinance in this matter actually does impose criminal penalties. Cook County Code of Ordinances Sec. 34-85
(incorporated by Cook County Code of Ordinances Sec. 74-858).
5
Curiously, Defendants have issued no regulations that implement or interpret Section 74-852(a). The absence of
such regulations not only undermines Defendants argument here, but also violates Section 74-859 which clearly
provides that the Department shall prescribe rules including but not limited to tax deductions/credits for
breakage, spoilage, spillage, sweetened beverage expiration, sweetened beverage destruction and tax free sales.
Such failure of Defendants to comply with the Ordinance only emphasizes vagueness problem.

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 In addition to identifying the impermissible vagueness of the imposition provisions of the

Ordinance, the Complaint also plainly alleges numerous other vague provisions, as stated below.

The ordinance is inconsistent with the Supplemental Nutrition Assistance

Program (SNAP). 6 See Complaint at 49-55.

The Ordinance is inconsistent with the Chicago of Chicago Alternative Pricing

Rules. See Complaint at 66.

The Ordinance is inconsistent with the Illinois Retailers Occupation Tax. See

Complaint at 67.

These issues, in addition to being in conflict with the imposition clause, Section 74-852(a), also

conflict with the provisions requiring the tax to be borne by the purchaser of the sweetened
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beverage, Section 74-852(b), and requirement that the distributor and retailer include the tax in
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the sale price and not absorb the tax, Section 74-852(c). Defendants, however, attempt to

explain away the clear conflicts of the Ordinance with other applicable laws (known to

Defendants when the Tax was adopted) by citing their recently issued regulations. 7 Not only are

such regulations subject to change, as evidenced by Defendants reversal of positions and

unpublicized revisions, but the regulations even conflict with the Ordinance. See Complaint at

62. For example, Regulation 2017-4 is a change in position by Defendants regarding the

6
It should be noted that Defendants argue that because the Ordinance specifically requires the collection of tax
unless otherwise required by law. (D. Motion at p. 14). But that cited provision does not apply to the collection
of tax. Instead, the caveat for unless otherwise required by law applies to the inclusion of the Tax in the sale
price of the sweetened beverage. See Section 74-852(c). The Ordinance does not provide any exception,
exemption or exclusion from the collection of the Tax for purchases using SNAP. Defendants allegations to the
contrary are disingenuous.
7
For example, Defendants admit that the Ordinance is silent as to the treatment of purchases using SNAP, but once
Defendants made up their mind, they issued Regulation 2017-3. (D. Motion at p. 14). Similarly, the conflict with
the City of Chicagos Alternative Pricing Rules is solved, according to Defendants, by Regulation 2017-2. (D.
Motion at p. 14). With respect to the Illinois Retailers Occupation Tax, Defendants also contend the concerns are
addressed by Regulation 2017-2. (D. Motion at p. 15).

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 taxability of purchases using SNAP. See Complaint at 55. This point only serves to

demonstrate the vagueness that plagues the Ordinance and requires that the Tax be found invalid.

Finally, as unintentionally cited by Defendants, courts tolerance for vague laws is even

greater where there are criminal liabilities associated with the law. See, e.g., Wilson v. County of

Cook, 2012 IL 112026, 23 (2012). As alleged in the Complaint, retailers may be subject to qui

tam, class action and/or criminal liabilities for under collection and over collection of the Tax.

See Complaint at 61; Cook County Code of Ordinances Sec. 34-85 (incorporated by Cook

County Code of Ordinances Sec. 74-858). Nevertheless, the Complaints allegations of fact and

law, if proven, clearly provide that the Ordinance is impermissibly vague regardless of whether it

is a civil or criminal law.

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Accordingly, accepting all well-pled facts as true and construing the allegations in the
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light most favorable to Plaintiff, the inescapable conclusion is that the Ordinance is

unconstitutionally vague. Indeed, because the Complaint sufficiently pleads facts that a retailers

responsibilities are so unclear under the Ordinance it is impossible for retailers, including

Plaintiffs, to comply with any precision or intelligible application with the Tax in the manner

contemplated by the Ordinance, Defendants Motion should be denied.

IV. CONCLUSION

Plaintiffs Complaint sufficiently alleges facts and law that, if proven, would entitle

Plaintiffs to the relief sought. Defendants, in bringing a section 2-615 motion to dismiss, also

seek to introduce facts that are not properly considered in determining whether the pleadings

meet minimum standards. Defendants Motion should be denied, as it is nothing more than

Defendants improper attempt to litigate the merits of the case.

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 WHEREFORE, for the foregoing reasons, Plaintiffs, Illinois Retail Merchants

Association, Berkot, Ltd. d/b/a Berkot Super Foods; Fairplay, Inc. d/b/a Fairplay Foods; Chiquita

Food Market, Inc. d/b/a Food Market La Chaquita & Taqueria; Leamington Foods, Inc.; Tonys

Finer Foods Enterprises, Inc. d/b/a Tonys Fresh Market; Valli Produce, Inc.; and Walts

Lagestee, Inc. d/b/a Walts Food Centers, respectfully request that this Court deny Defendants

Section 2-615 Motion to Dismiss Plaintiffs Verified Complaint, and order Defendants to file a

Verified Answer, and for any additional relief this Court deems just.

Respectfully submitted,

ILLINOIS RETAIL MERCHANTS

ASSOCIATION, BERKOT, LTD. d/b/a
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BERKOT SUPER FOODS; FAIRPLAY, INC.

d/b/a FAIRPLAY FOODS; CHIQUITA FOOD
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MARKET, INC. d/b/a FOOD MARKET LA

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CHAQUITA & TAQUERIA; LEAMINGTON

FOODS, INC.; TONYS FINER FOODS
ENTERPRISES, INC. d/b/a TONYS FRESH
MARKET; VALLI PRODUCE, INC.; AND
WALTS LAGESTEE, INC. d/b/a WALTS
FOOD CENTERS

Plaintiffs.

By:/s/Marilyn A. Wethekam
One of Their Attorneys

Marilyn A. Wethekam (mwethekam@hmblaw.com)

Jordan M. Goodman (jgoodman@hmblaw.com)
David S. Ruskin (druskin@hmblaw.com)
HORWOOD MARCUS & BERK CHARTERED
500 West Madison Street, Suite 3700
Chicago, Illinois 60661
Telephone: (312) 606-3200
Attorney No. 34957

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 CERTIFICATE OF SERVICE

The undersigned hereby certifies that she caused a true and correct copy of the foregoing,

PLAINTIFFS RESPONSE IN OPPOSITION TO DEFENDANTS MOTION TO

DISMISS, to be served on other counsel of record listed below by electronic mail on this 14th

day of July, 2017, addressed as follows:

Sisavanh Baker
James S. Beligratis
Assistant States Attorneys
500 Richard J. Daley Center
Chicago, Illinois 60602
Sisavanh.baker@cookcountyil.gov
James.Beligratis@cookcountyil.gov
Attorneys for Defendants-Petitioners
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/s/ Megan E. OConnell_________

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