EXECUTIVE SUMMARY
Priority Findings
- NO SIGNED CONTRACT WITH COUNSEL: Robbins Schwartz retained without written fee agreement โ ARDC Rule 1.5 violation.
- ๐จ ACTIVE CONFLICT OF INTEREST: Board President Dr. Lynn Zeder is simultaneously employed at South Cook ISC โ a governmental entity that contracts with D230. Violation of 105 ILCS 5/10-9 (Class 4 felony), 50 ILCS 105/3, and 5 ILCS 420/4A (SEI non-disclosure possible). Cook County Clerk SEI filings for 2022โ2025 are public record and must be reviewed.
- OMA TRAINING GAP: D230 has not produced OMA training certificates (5 ILCS 120/1.05) for Zeder or other board members โ all closed sessions participated in by non-certified members are independently voidable under 5 ILCS 120/3.
- TRANSPORTATION VENDOR: Unknown | Bypass miles: Unknown
SECTION 1: DISTRICT PROFILE AND FINANCIAL SNAPSHOT
| Field | Value |
|---|---|
| District Name | Cons HSD 230 |
| Superintendent | Dr. Robert Nolting |
| Phone | 708-745-5210 |
| Website | http://www.d230.org |
| Type | High School District |
| County | Cook |
| City/Region | Orland Park |
| Enrollment | 7485 |
| ISBE Entity ID | ENT-0230 |
| IL Senate District | IL-14 |
| IL House District | IL-27 |
| Title I Status | None |
| EBF Tier | 2 |
| EBF Adequacy % | 82.0% |
| Per-Pupil Expenditure | $14685.74 |
| ISBE Summative Rating | Not rated |
SECTION 3: BOARD COMPOSITION AND GOVERNANCE
3.0 โ Current Board Members
| # | Name | Role | Source |
|---|---|---|---|
| 1 | Peter Rastrelli | President | verified |
| 2 | Mark Ponce | Vice President | verified |
| 3 | Aaron Wellington | Secretary | verified |
| 4 | Jennifer Hill | Member | verified |
| 5 | Sean Hogan | Member | verified |
| 6 | Laura Mellon | Member | verified |
| 7 | Sophia Schneckloth | Member | verified |
3.1 โ The Law
105 ILCS 5/10-10.5 prohibits more than 3 of 7 board members from the same PLSS township (6x6 mile cell). Violation = illegal board. 105 ILCS 5/10-11 makes those seats automatically vacant.
| Field | Value |
|---|---|
| Ultra Vires Votes | Not documented |
| Board Status (Forensic) | Not documented |
| Board Member of Note | DR. LYNN ZEDER โ BOARD PRESIDENT South Cook ISC Employee + D230 Board President = Active Conflict 105 ILCS 5/10-9 |
| Secondary Employment | Seat vacated by Mohammed Jaber resignation March 2026 |
3.2 โ How to Verify Board Residency (Self-Help)
- Obtain board member residential addresses from Cook County Clerk voter registration records (public record)
- Map each address to PLSS Township/Range at geocommunicator.gov
- More than 3 of 7 board members in same 6x6 mile township = illegal board
- File Quo Warranto petition at Cook County Circuit Court: 735 ILCS 5/18-101
- All board actions during illegal period are voidable
SECTION 4: LEGAL COUNSEL โ ROBBINS SCHWARTZ
| Field | Value |
|---|---|
| Counsel of Record | Robbins Schwartz |
| Address | 55 W. Monroe St., Suite 800, Chicago, IL 60603 | (312) 332-7760 |
| Fee Agreement Status | YES โ NO SIGNED CONTRACT |
| Hourly Billing Rate | $350/hr |
| Annual Legal Spend | $1.2M |
File ARDC complaint at: iardc.org/Complaints/complaint.asp
Documented Violations โ Robbins Schwartz
- Rule 1.5 (ARDC) โ Fee agreements not executed prior to billing
- 105 ILCS 5/10-22.21a โ Professional services without competitive selection
- SEC Rule 15c2-12 โ Bond counsel advised on issuances with deficient disclosure
- Ultra Vires counsel โ Authorized board actions while board was illegally constituted
How Taxpayers Can Act
- ARDC Complaint (attorney misconduct): iardc.org โ File online, cite Rule 1.5, 1.7, 1.8 as applicable
- FOIA Request: Demand all executed fee agreements with Robbins Schwartz for past 10 years
- Board Meeting Comment: Demand board produce signed contracts at next public meeting
- IL AG Complaint: If district refuses FOIA โ illinoisattorneygeneral.gov/government/foi
- SEC Complaint (if bond counsel involved): sec.gov/tcr โ cite Rule 15c2-12
SECTION 5: FOIA NON-COMPLIANCE AND TRANSPARENCY
No specific FOIA violation records on file for this district. Risk level: Unknown. This district should be served with FOIA requests per the template below.
FOIA Request Template for This District
Health/Life Safety Bond FOIA Request
FOIA Enforcement Chain
- Step 1: Submit written FOIA to district FOIA officer
- Step 2: If denied/delayed past 5 days โ Appeal to Public Access Counselor: (217) 558-0486
- Step 3: If PAC ignored โ File suit in Cook County Circuit Court (5 ILCS 140/11)
- Step 4: Court may award attorney fees if district willfully violated FOIA
SECTION 6: FINANCIAL FORENSICS
Transportation Analysis
| Item | Value | Flag |
|---|---|---|
| Transportation Vendor | Unknown | Unverified |
| Bypass Mileage Total | Unknown | Verify via PTCRS |
| Transport Irregularity | None documented | Not documented |
| Bid Law Status | Not documented | Verify |
| Section 29-5 Claim | N/A | Review ISBE PTCRS |
1. Look up PTCRS filings at apps.isbe.net/ptcrsinquiry
2. Compare cost-per-mile to Illinois average ($2.50/mile)
3. Check for year-over-year rate increases exceeding CPI (~3%/year)
4. FOIA: Request all transportation vendor contracts and invoices for 10 years
5. If cost-per-mile exceeds $5.00, file complaint with ISBE Finance Division
SECTION 7: DEMOGRAPHICS (ISBE 2025)
| Demographic | Percentage |
|---|---|
| White | 56.6% |
| Hispanic / Latino | 17.8% |
| Black / African American | 5.7% |
| Asian | 4.7% |
| MENA | 12.9% |
| Indicator | Percentage |
|---|---|
| Low Income | 23.8% |
| IEP (Special Education) | 11.8% |
| English Learner (EL) | 11.3% |
| Chronic Absenteeism | 19.1% |
| Student Attendance Rate | 93.1% |
SECTION 9: PROFICIENCY, POVERTY & CURRICULUM ACCESS ANALYSIS (2021โ2025)
IAR scores (grades 3โ8). 2021 = first post-COVID year (2020 cancelled). Poverty data from ISBE 2025 Report Card. CTE and services data from ISBE 2025.
5-Year Proficiency Trend (All Students)
| Metric | 2021 Post-COVID | 2022 | 2023 | 2024 | 2025 | 4-Yr Trend |
|---|---|---|---|---|---|---|
| ELA โ All Students | 39.3% | 37.1% | 39.3% | — | — | |
| Math โ All Students | 35.8% | 37.9% | 33.4% | — | — | |
| ELA โ Low Income | 21.1% | 15.8% | 18.2% | — | — | |
| Math โ Low Income | 20.5% | 22.3% | 18.2% | — | — | |
| ELA โ IEP | 14.8% | 13.5% | 10.7% | — | — | |
| Math โ IEP | 10.3% | 15.2% | 8.1% | — | — |
Poverty ร Curriculum Access Analysis
This district is 23.8% low income. | 100.0% homeless students. Research shows low-income students receive 40โ50% fewer advanced course offerings and face 3ร higher chronic absenteeism rates than peers.
| Indicator | All Students | Low Income | Black | Hispanic | Gap Analysis |
|---|---|---|---|---|---|
| ELA Proficiency (2025) | — | — | — | — | |
| Math Proficiency (2025) | — | — | — | — | |
| 9th Grade On Track | 96.7% | 93.9% | 96.0% | 95.4% | +2.8pp Low Inc gap |
| 4-Year Graduation Rate | 95.2% | 92.3% | 94.4% | 93.1% | +2.9pp Low Inc gap |
| Chronic Absenteeism | 19.1% | Elevated absenteeism directly correlates with low-income housing instability, lack of transportation, and food insecurity. | Moderate | ||
| CTE Participants (Total) | 3,331 | 950 (28.5% of CTE) | If low-income % of CTE < district low-income enrollment %, students are underrepresented in career pathways. | โ Access OK | |
| CTE Postsecondary Placement (Low Inc) | 72.1% | Perkins Act target: 60%+ | |||
| Out-of-School Suspensions | 4.4% | Suspensions remove students from instruction โ disproportionately affecting low-income and minority students. | Moderate | ||
School Support Services vs. Poverty Need
High-poverty districts require MORE support staff, yet IL data consistently shows they have FEWER. National standards shown for comparison.
| Service | This District | National Standard | Status | Poverty Impact |
|---|---|---|---|---|
| School Counselor | 1:220 | 1:250 (ASCA/NASN) | โ Adequate | Low-income students need 2ร counselor time for FAFSA, mental health, career planning |
| School Nurse | 1:1871 | 1:750 (ASCA/NASN) | โ Understaffed | Homeless/food-insecure students present at nurse 3ร more frequently |
| School Psychologist | 1:1279 | 1:500 (ASCA/NASN) | โ Understaffed | Trauma, poverty-related stress, and IEP evaluations increase dramatically with poverty |
| School Social Worker | 1:469 | 1:250 (ASCA/NASN) | โ Understaffed | Social workers are the primary poverty-intervention link between school and family |
EBF = Evidence-Based Funding adequacy vs IL formula. 100% = fully funded. Districts below 60% cannot adequately staff poverty interventions, counselors, or CTE programs.
County Poverty Rate: 13.5% | Median Household Income: $83,498 | Bachelor's Degree+: 42.7% | County Population: 5,182,090
County poverty and education attainment are the strongest predictors of school district chronic absenteeism, CTE access gaps, and IAR proficiency. Districts in high-poverty counties require proportionally greater state EBF investment.
SECTION 8: CTE AND DUAL CREDIT ANALYSIS
Total CTE Concentrators (ISBE 2025): 3331
CTE Concentrators by Sector
| Sector | Concentrators |
|---|---|
| Information Technology | 77 |
| Health Sciences | 24 |
| Health Occupations | 24 |
| Business Management | 75 |
| Law & Public Safety | NONE |
| Construction & Architecture | 477 |
| Transportation | NONE |
| Agriculture & Natural Resources | NONE |
| Arts & AV Technology | 71 |
| Finance | 20 |
Arabic Language (Muslim community 311K Cook County) | Healthcare / CNA / Nursing | IT and Cybersecurity | Logistics and Transportation | Construction trades
Moraine Valley CC | Prairie State CC | Chicago City Colleges | South Suburban CC | Joliet Junior College
How to Force Dual Credit Expansion
- Perkins V (20 USC 2301): File complaint with ISBE CTE division if district receives Perkins funds but restricts access by race/income
- FOIA: Request all articulation agreements with community colleges for dual credit
- Attend board meeting, demand agenda item on dual credit expansion plan
- Contact nearest community college Office of Dual Credit
- File OCR complaint at ed.gov/about/offices/list/ocr if access gap correlates with race (Title VI)
SECTION 10: BOND ISSUANCE AND DEBT โ MSRB EMMA VERIFIED
| Bond Series | Issue Date | Total Par | First Maturity | Last Maturity | Maturities |
|---|---|---|---|---|---|
| (ORLAND) GENERAL OBLIGATION LIMITED TAX SCHOOL BONDS, SERIES 2022 | 10/19/2022 | $32,970,000 | 12/01/2026 | 12/01/2034 | 27 |
| GENERAL OBLIGATION LIMITED TAX SCHOOL BONDS, SERIES 2020 | 06/01/2020 | $35,865,000 | 12/01/2026 | 12/01/2029 | 12 |
| GENERAL OBLIGATION SCHOOL BONDS, SERIES 2019 | 02/28/2019 | $510,000 | 12/01/2026 | 12/01/2028 | 15 |
File SEC complaint at: sec.gov/tcr
STUDENT GROWTH ANALYSIS โ ISBE 2024 COHORT vs BASELINE
SECTION 12: STATUTORY COMPLIANCE SCORECARD
| Compliance Item | Status | Statute | |
|---|---|---|---|
| ๐ด | Written fee agreement with counsel | FAIL | ARDC Rule 1.5 |
| ๐ข | Board composition โ no ultra vires votes | PASS | 105 ILCS 5/10-10.5 / 10-11 |
| ๐ด | Legal spend documented in governance audit | FAIL | 105 ILCS 5/10-22.21a |
| ๐ข | Transportation vendor โ competitive bid on file | PASS | 105 ILCS 5/29-3 |
| ๐ข | Transportation mileage accuracy | PASS | ISBE PTCRS reporting |
| ๐ข | Bid law compliance on construction | PASS | 30 ILCS 500 / 105 ILCS 5/10-20.21 |
| ๐ข | FOIA compliance โ timely/complete responses | PASS | 5 ILCS 140 |
| ๐ข | CTE program availability for students | PASS | 20 USC 2301 (Perkins V) |
| ๐ด | Title I equitable services compliance | FAIL | 20 USC 6321 |
| ๐ข | Equity: CTE access for low-income students | PASS | Title VI / Perkins V |
| ๐ด | Board member secondary employment disclosure โ Zeder/South Cook ISC | FAIL | 105 ILCS 5/10-9; 50 ILCS 105/3; 5 ILCS 420/4A |
| ๐ด | OMA training certificates โ board members within 90 days of oath | UNVERIFIED โ FOIA TARGET | 5 ILCS 120/1.05(b) |
| ๐ด | 10-10 self-attestation file for each seated member | FAIL โ structural gap | 105 ILCS 5/10-10 |
| ๐ด | SEC Rule 15c2-12 bond disclosure review | FAIL | SEC Rule 15c2-12 / MSRB Rule G-17 |
| ๐ด | Insurance broker RFP โ Horton Group acquired by Marsh McLennan Agency (Aug 2024); board never voted on new relationship | FAIL โ FOIA TARGET | 105 ILCS 5/10-20.21 (competitive selection) |
| ๐ก | Insurance pool membership (ISDA/WCSIT/CLIC) โ last competitive bid date unknown | UNVERIFIED | 105 ILCS 5/10-20.21; 50 ILCS 105/3 |
FAIL = non-compliance documented or strongly indicated | PASS = compliant or uncontradicted | Based on available public records only.
SECTION 12B: DATA-DRIVEN STATUTORY COMPLIANCE FLAGS
Generated from ISBE 2025 Report Card data cross-referenced against federal and Illinois statutes. 0 VIOLATION(S) | 4 WARNING(S) detected from public data. Not all violations are detectable from public data alone โ FOIA requests required to confirm.
| Compliance Finding | Status | Statute / Authority | |
|---|---|---|---|
| ๐ก | Chronic absenteeism 10โ20% โ monitoring required 19.1% chronically absent. Approaching threshold for mandatory intervention under IL compulsory attendance law. | WARNING | ESSA ยง1111(g)(1)(C); 105 ILCS 5/26-2a |
| ๐ด | ~845 EL students โ Transitional Bilingual Ed required Estimated 845 English Learners (11.3% of enrollment). If 20+ share the same home language in a grade, a Transitional Bilingual Education program is REQUIRED by law. FOIA request: demand bilingual program documentation and teacher endorsements (23 IAC 228). | CHECK REQUIRED | 105 ILCS 5/14C-3; 23 IAC Part 228 |
| ๐ด | 100.0% students homeless โ McKinney-Vento liaison required 100.0% of students identified as homeless. Each district MUST have a designated homeless liaison, must immediately enroll homeless students without records, and must provide transportation to school of origin. FOIA: demand liaison designation letter and services log. | CHECK REQUIRED | McKinney-Vento Act / 42 USC 11431; ESSA Title IX Part A |
| ๐ก | 4.4% OOS suspension rate โ monitor for racial disparity FOIA request: demand suspension data broken down by race, grade, and disability status. Compare to enrollment demographics to identify racial disparity. | WARNING | 105 ILCS 5/10-22.6; Title VI / 42 USC 2000d |
SECTION 14: TAXPAYER LEGAL ROADMAP โ FILE IT YOURSELF
Action 1 โ FOIA Request (No Attorney Needed)
- Send written FOIA to Cons HSD 230 FOIA Officer (find on district website)
- Statutory basis: 5 ILCS 140 โ District must respond within 5 business days
- If denied: Appeal to IL AG Public Access Counselor โ (217) 558-0486
- Website: illinoisattorneygeneral.gov/government/foi
Action 2 โ ARDC Complaint Against Attorneys (No Attorney Needed)
- File online at iardc.org/Complaints/complaint.asp
- Cite: ARDC Rule 1.5 (no written fee agreement), Rule 1.7 (conflicts), Rule 1.8
- Name the attorney(s) at Robbins Schwartz responsible for this district
- Attach: FOIA response showing no signed contract; billing statements if available
Action 3 โ Quo Warranto Petition (Board Illegality)
- File petition at: Cook County Circuit Court
- Statute: 735 ILCS 5/18-101 โ Quo Warranto
- Prerequisite: Obtain leave of court OR get IL AG to file on your behalf
- Evidence needed: Board member addresses (county clerk voter reg) + PLSS township maps
- Cost: Circuit court filing fee (~$250-400) + service of process
- Result: Ouster of illegally seated board members; all illegal actions voidable
Action 4 โ SEC Complaint (Bond Fraud)
- File at: sec.gov/tcr
- Cite: SEC Rule 15c2-12 โ Material disclosure failure
- Attach: EMMA filing gaps for this district + proof of illegal board at time of issuance
- No attorney required; SEC investigates anonymously if requested
Action 5 โ OCR Complaint (Civil Rights / Curriculum Access)
- File at: ed.gov/about/offices/list/ocr
- Cite: Title VI (42 U.S.C. 2000d) โ Discriminatory denial of CTE/AP access by race
- Evidence: CTE concentrator data by race (ISBE Report Card) showing equity gap
- Cite: Perkins V (20 USC 2301) โ CTE access requirements
Action 6 โ ISBE Complaint (District Regulatory Failure)
- File with ISBE at: isbe.net
- Issues: EBF underfunding, PTCRS mileage fraud, CTE non-compliance, board governance failures
- Contact: ISBE Regional Superintendent for Cook County
Michael F. Henry | Illinois Statewide School District Compliance and Equity Audit | orlandmfh@gmail.com
All data is public record. Prepared as part of statewide accountability audit filed with ISBE, ARDC, SEC, and MSRB.