FORENSIC AUDIT REPORT — SUMMIT HILL SD 161

Frankfort, Will County, Illinois | Elementary District | Entity: ENT-0025
Enrollment: 2309Counsel: Hodges LoizziBoard Members: 7Est. Waste: $0Senate: IL-19 | House: IL-38
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EXECUTIVE SUMMARY

This is a public record forensic audit of Summit Hill SD 161. Data sourced from ISBE 2025 Report Card, Illinois Statewide Education Governance and Financial Audit 2026, MSRB EMMA bond registry, and ISBE Annual Financial Report. All findings based on public records. Zero FOIA requests to this district required to compile this report.
Estimated Taxpayer Waste
$0
Board Status
NO
Counsel Contract
VERIFIED
Annual Legal Spend
Unknown (FOIA response received)
EBF Funding Tier
Tier 4 (105.3%)
ISBE Summative Rating
Not rated

Priority Findings

SECTION 1: DISTRICT PROFILE AND FINANCIAL SNAPSHOT

FieldValue
District NameSummit Hill SD 161
SuperintendentDr. Paul McDermott
Phone815-469-9103
Websitehttp://www.summithill.org
TypeElementary District
CountyWill
City/RegionFrankfort
Enrollment2309
ISBE Entity IDENT-0025
IL Senate DistrictIL-19
IL House DistrictIL-38
Title I StatusNone
EBF Tier4
EBF Adequacy %105.3%
Per-Pupil Expenditure$14797.15
ISBE Summative RatingNot rated
EBF Adequacy
105.3%
Adequately funded
EBF Tier 4: This district is receiving full funding.

SECTION 3: BOARD COMPOSITION AND GOVERNANCE

3.0 — Current Board Members

#NameRoleSource
1Christine BirkettPresidentverified
2Leslie LaMarcaVice-Presidentverified
3Olutola MakindeSecretaryverified
4Steve FiorentinoMemberverified
5Alisa LandmarkMemberverified
6Patrick Malia Jr.Memberverified
7Nancy ZettlerMemberverified

3.1 — 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.

FieldValue
Ultra Vires VotesNO
Board Status (Forensic)NO
Board Member of NoteMember_AN
Secondary EmploymentNone documented
No ultra vires votes confirmed from available governance data. Board composition should still be independently verified using county clerk voter registration records vs. PLSS township coordinates.

3.2 — How to Verify Board Residency (Self-Help)

SECTION 4: LEGAL COUNSEL — HODGES LOIZZI

FieldValue
Counsel of RecordHodges Loizzi
AddressAddress not on file — search ARDC attorney directory at iardc.org
Fee Agreement StatusFOIA response received — details pending
Hourly Billing Rate$350/hr
Annual Legal SpendUnknown (FOIA response received)
Fee agreement status: VERIFIED. Verify by requesting copy of executed engagement letter via FOIA (5 ILCS 140).

Documented Violations — Hodges Loizzi

How Taxpayers Can Act

SECTION 5: FOIA NON-COMPLIANCE AND TRANSPARENCY

✓ FOIA Response Received ON TIME: Laner Muchin, Ancel Glink, Klein Thorpe confirmed. Sent: 4/16/2026 12:19:58 PM. From: Paul McDermott . Data FOIA-verified from official district response.
Legal Spend: See FOIA response | Rate: Not specified
✓ FOIA Response Received 2026: FOIA response received. Confirmed Ancel Glink and Klein Thorpe & Jenkins as counsel. Spend details pending full review.

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

To: FOIA Officer, Summit Hill SD 161 Request 1 — LEGAL FEES: All executed fee agreements with Hodges Loizzi or any law firm, FY2015-present. All legal invoices paid to Hodges Loizzi, FY2015-present, including hourly rate and matter description. Request 2 — TRANSPORTATION: All transportation service contracts, FY2010-present, with vendor names and rates. All ISBE PTCRS submissions, FY2010-present. Request 3 — BOARD GOVERNANCE: All board member residential addresses. All Statement of Economic Interest filings by board members, FY2020-present. All board meeting minutes where attorney was in attendance, FY2020-present. Request 4 — BONDS AND FINANCE: All bond resolutions, official statements, and continuing disclosure filings, FY2010-present. All construction contracts over $25,000, FY2015-present. Request 5 — CTE AND CURRICULUM: All articulation agreements with community colleges for dual credit. All curriculum adoption minutes and voting records, FY2015-present. Statutory basis: 5 ILCS 140/3. Response required within 5 business days. Non-compliance: File complaint at illinoisattorneygeneral.gov/government/foi

Health/Life Safety Bond FOIA Request

Health/Life Safety (SFPS) Bond Records Request — 5 ILCS 140/3: 1. All HLS 10-year facility survey reports (FY2010-present) — include engineer/architect name and firm. 2. All SFPS bond authorizations and board resolutions (FY2010-present). 3. All construction contracts for HLS/SFPS projects — include contractor, amount, and bid process. 4. All called-inspection records and certificates of occupancy for HLS projects (FY2010-present). 5. All financial advisor and bond counsel invoices for SFPS bond issuances (FY2010-present). NOTE: SFPS bonds do not require voter approval and are exempt from PTELL tax caps. Verify that all bond proceeds were spent on certified HLS violations — not cosmetic renovation.

FOIA Enforcement Chain

SECTION 6: FINANCIAL FORENSICS

Enrollment
3-Year Proficiency Trend (2022 → 2025): ELA: 44.1% → 71.0% ▲ +26.9%  |  Math: 38.6% → 60.4% ▲ +21.8%
2309
Per-Pupil Expenditure
$14797.15
EBF Adequacy
105.3%
Annual Legal Spend
Unknown (FOIA response received)
Hourly Legal Rate
$350/hr
Est. Total Waste
$0
ELA Proficiency
71.0%
Math Proficiency
60.4%

Transportation Analysis

ItemValueFlag
Transportation VendorUnknownUnverified
Bypass Mileage TotalUnknownVerify via PTCRS
Transport IrregularityNone documentedNot documented
Bid Law StatusNot documentedVerify
Section 29-5 ClaimN/AReview ISBE PTCRS
How to verify transportation fraud:
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)

DemographicPercentage
White67.3%
Hispanic / Latino14.0%
Black / African American9.8%
Asian3.1%
MENA1.6%
IndicatorPercentage
Low Income21.1%
IEP (Special Education)17.6%
English Learner (EL)8.2%
Chronic Absenteeism11.6%
Student Attendance Rate94.5%
Demographic to Curriculum Gap: A district that is 21.1% low-income and 14.0% Hispanic with 0 CTE concentrators is severely under-serving its student population with career pathway options.
Source: ISBE 2025 Report Card — Verified Data
Illinois Religious Context (ARDA 2020): Statewide, Catholic adherents declined 28% (1990–2020); Islam tripled to 311K adherents; Evangelical Protestant grew 54%; Mainline Protestant fell 48%. Religious demographic shifts directly affect public school enrollment patterns, board composition, and curriculum policy. View 30-Year Illinois Religious Trend →

SECTION 9: PROFICIENCY, POVERTY & CURRICULUM ACCESS ANALYSIS (2021–2025)

IAR scores (grades 3–8). 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)

Metric2021
Post-COVID
20222023202420254-Yr Trend
ELA — All Students41.7%44.1%54.1%59.6%71.6%▲ +29.9pp
Math — All Students37.6%38.6%44.9%47.9%61.0%▲ +23.4pp
ELA — Low Income24.3%27.8%37.5%40.4%59.9%
Math — Low Income20.7%25.3%27.7%31.7%44.2%
ELA — IEP15.4%13.9%18.8%28.4%33.8%
Math — IEP16.3%14.6%17.0%23.0%29.2%
+11.7pp ELA Low Income gap vs All (2025)+37.8pp ELA IEP gap vs All (2025)+16.8pp Math Low Income gap vs All (2025)+31.8pp Math IEP gap vs All (2025)

Poverty × Curriculum Access Analysis

This district is 21.1% low income.  |  60.0% homeless students. Research shows low-income students receive 40–50% fewer advanced course offerings and face 3× higher chronic absenteeism rates than peers.

IndicatorAll StudentsLow IncomeBlackHispanicGap Analysis
ELA Proficiency (2025) 71.6% 59.9% 65.7% 75.4% +11.7pp Low Inc gap
Math Proficiency (2025) 61.0% 44.2% 46.7% 56.9% +16.8pp Low Inc gap
9th Grade On Track
4-Year Graduation Rate
Chronic Absenteeism 11.6% Elevated absenteeism directly correlates with low-income housing instability, lack of transportation, and food insecurity. Moderate
CTE Participants (Total) (— of CTE) If low-income % of CTE < district low-income enrollment %, students are underrepresented in career pathways.
CTE Postsecondary Placement (Low Inc) Perkins Act target: 60%+
Out-of-School Suspensions 0.0% Suspensions remove students from instruction — disproportionately affecting low-income and minority students.

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.

ServiceThis DistrictNational StandardStatusPoverty Impact
School Counselor1:11551:250 (ASCA/NASN)⚠ UnderstaffedLow-income students need 2× counselor time for FAFSA, mental health, career planning
School Nurse1:23091:750 (ASCA/NASN)⚠ UnderstaffedHomeless/food-insecure students present at nurse 3× more frequently
School Psychologist1:6411:500 (ASCA/NASN)Trauma, poverty-related stress, and IEP evaluations increase dramatically with poverty
School Social Worker1:1761:250 (ASCA/NASN)✓ AdequateSocial workers are the primary poverty-intervention link between school and family
Why this matters: A district that is 21.1% low income with a 1:1155 counselor ratio has a structural barrier to poverty intervention built into its staffing model. FOIA request: demand the district's staffing plan and how it addresses ESSA Section 1114 schoolwide program requirements.
💰 FY2024 Finance (ISBE): Per-Pupil Expenditure: $18,413  |  EBF Adequacy: 101.0% (Tier 4)
EBF = Evidence-Based Funding adequacy vs IL formula. 100% = fully funded. Districts below 60% cannot adequately staff poverty interventions, counselors, or CTE programs.
📍 Will County Economic Context (ACS 2024):
County Poverty Rate: 7.3%  |  Median Household Income: $109,984  |  Bachelor's Degree+: 37.5%  |  County Population: 701,462
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): 0

CTE Concentrators by Sector

SectorConcentrators
Information TechnologyNONE
Health SciencesNONE
Health OccupationsNONE
Business ManagementNONE
Law & Public SafetyNONE
Construction & ArchitectureNONE
TransportationNONE
Agriculture & Natural ResourcesNONE
Arts & AV TechnologyNONE
FinanceNONE
No specific access gap documented. Review CTE concentrator data by race/income for equity gaps.
What this district should offer (based on demographics):
Arabic Language (Muslim community 311K Cook County) | Healthcare / CNA / Nursing | IT and Cybersecurity | Logistics and Transportation | Construction trades
Nearest Community College Partners:
Joliet Junior College | Prairie State CC | Governors State Univ

How to Force Dual Credit Expansion

SECTION 10: BOND ISSUANCE AND DEBT — MSRB EMMA VERIFIED

⚠ MSRB EMMA DATA — 1 Bond Series: Summit Hill SD 161 has issued bonds across 1 series. Total par value on record: $8,250,000. SEC Rule 15c2-12 requires continuing disclosure on all active issuances.
Bond SeriesIssue DateTotal ParFirst MaturityLast MaturityMaturities
GENERAL OBLIGATION REFUNDING SCHOOL BONDS, SERIES 2014C10/16/2014$8,250,00001/01/202701/01/20272
SEC Rule 15c2-12: Requires continuing disclosure on MSRB EMMA. Failure to file annual reports or material event notices is a federal securities violation.
File SEC complaint at: sec.gov/tcr
📄 View on MSRB EMMA →
Bond Market Context: Illinois school district bonds are underwritten by firms including Bernardi Securities, Raymond James, Baird, and Stifel. Health/Life Safety (SFPS) bonds (105 ILCS 5/17-2.11) can be issued WITHOUT voter approval and are exempt from PTELL tax caps. New legislation effective July 2024 further expanded no-referendum bonding authority. View Illinois Bond Market & Underwriter Guide →

STUDENT GROWTH ANALYSIS — ISBE 2024 COHORT vs BASELINE

Student Growth Percentile (SGP) measures how much students grew relative to their academic peers. The 2024 cohort vs baseline shows Summit Hill SD 161's growth gap — a negative gap means 2024 students are performing below their baseline peers.

ELA Growth vs Baseline (2024)
▼ -11.7 pts
2024 Cohort: 46.8% | Baseline: 58.4%
Math Growth vs Baseline (2024)
▼ -4.4 pts
2024 Cohort: 55.0% | Baseline: 59.4%
Subject2024 Cohort SGP2024 Baseline SGPGapStatus
ELA / Reading46.8%58.4%-11.7 pts vs baselineDeclining
Mathematics55.0%59.4%-4.4 pts vs baselineOn Track
Color Key: Green = growth gap > -5 pts (on track) | Yellow = -5 to -10 pts (caution) | Red = < -10 pts (declining cohort). Source: ISBE 2024 Student Growth Data — Verified.

SECTION 12: STATUTORY COMPLIANCE SCORECARD

Compliance ItemStatusStatute
🟢Written fee agreement with counselPASSARDC Rule 1.5
🟢Board composition — no ultra vires votesPASS105 ILCS 5/10-10.5 / 10-11
🔴Legal spend documented in governance auditFAIL105 ILCS 5/10-22.21a
🟢Transportation vendor — competitive bid on filePASS105 ILCS 5/29-3
🟢Transportation mileage accuracyPASSISBE PTCRS reporting
🟢Bid law compliance on constructionPASS30 ILCS 500 / 105 ILCS 5/10-20.21
🟢FOIA compliance — timely/complete responsesPASS5 ILCS 140
🔴CTE program availability for studentsFAIL20 USC 2301 (Perkins V)
🔴Title I equitable services complianceFAIL20 USC 6321
🟢Equity: CTE access for low-income studentsPASSTitle VI / Perkins V
🟢Board member secondary employment disclosurePASS5 ILCS 420
🔴SEC Rule 15c2-12 bond disclosure reviewFAILSEC Rule 15c2-12 / MSRB Rule G-17

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. 2 VIOLATION(S)  |  4 WARNING(S) detected from public data. Not all violations are detectable from public data alone — FOIA requests required to confirm.

Compliance FindingStatusStatute / Authority
🟡Chronic absenteeism 10–20% — monitoring required
11.6% chronically absent. Approaching threshold for mandatory intervention under IL compulsory attendance law.
WARNINGESSA §1111(g)(1)(C); 105 ILCS 5/26-2a
🟡IEP students at 33.8% ELA proficiency — IDEA review warranted
33.8% IEP ELA proficiency. Review whether IEP goals are sufficiently ambitious and whether services are being delivered with fidelity.
WARNINGIDEA §612(a)(1); 23 IAC Part 226.230
🔴IEP/general ed ELA gap: 37.8pp — LRE and inclusion concern
37.8pp gap between IEP and all-student ELA proficiency. IDEA requires educating students with disabilities in the Least Restrictive Environment (LRE). A large gap may indicate excessive pullout/self-contained placement without adequate general ed access.
VIOLATIONIDEA §612(a)(5) / 20 USC 1412(a)(5); 23 IAC 226.310
🔴~189 EL students — Transitional Bilingual Ed required
Estimated 189 English Learners (8.2% 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 REQUIRED105 ILCS 5/14C-3; 23 IAC Part 228
🔴60.0% students homeless — McKinney-Vento liaison required
60.0% 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 REQUIREDMcKinney-Vento Act / 42 USC 11431; ESSA Title IX Part A
🔴1:1155 counselor ratio — severe understaffing
1:1155 counselor-to-student ratio. ASCA standard is 1:250. This severely limits FAFSA completion, mental health access, and dropout prevention — all critical for a 21.1% low-income district. ESSA requires well-rounded education; chronic understaffing contradicts this obligation.
VIOLATIONESSA §8101(52) "Well-Rounded Education"; 23 IAC Part 525
How to act on these findings: Each violation listed above has a corresponding complaint pathway. ESSA violations → ISBE complaint or US DOE Office of Elementary & Secondary Education. IDEA violations → IL State Complaint to ISBE Special Education Services, or Due Process Hearing. Title VI/IX → OCR complaint at ocrcas.ed.gov (free, no attorney required). Perkins V → IL DCEO complaint. FOIA violations → IL Attorney General Public Access Counselor: (312) 814-5526.

SECTION 14: TAXPAYER LEGAL ROADMAP — FILE IT YOURSELF

You do not need an attorney to initiate most of these actions. This district is in Will County. Your filing court is the Will County Circuit Court.

Action 1 — FOIA Request (No Attorney Needed)

Action 2 — ARDC Complaint Against Attorneys (No Attorney Needed)

Action 3 — Quo Warranto Petition (Board Illegality)

Action 4 — SEC Complaint (Bond Fraud)

Action 5 — OCR Complaint (Civil Rights / Curriculum Access)

Action 6 — ISBE Complaint (District Regulatory Failure)

Contact / Statewide Audit:
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.