In A.B.A.T.E. of Illinois, Inc. v. Quinn, 2011 IL 110611, the Illinois Supreme Court let stand an appellate court decision in which the Illinois General Assembly was allowed to take funds out of the Cycle Rider Safety Training Fund and transfer them into the General Revenue Fund, to be used for purposes other than cycle safety training programs. The Court ruled that the transfer of the funds did not constitute a “taking” of private funds without just compensation because the money set aside in the Training Funds were still considered public funds and therefore, the legislature had the authority to transfer them. The Court also ruled that one General Assembly need not be bound by promises to bikers made by previous General Assemblies.
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