EXECUTIVE SUMMARY
Priority Findings
- ULTRA VIRES BOARD: Board has documented ultra vires votes — all actions voidable under Illinois law.
- NO SIGNED CONTRACT WITH COUNSEL: Robbins Schwartz retained without written fee agreement — ARDC Rule 1.5 violation.
- SECONDARY EMPLOYMENT: None documented
- TRANSPORTATION VENDOR: Unknown | Bypass miles: Unknown
SECTION 1: DISTRICT PROFILE AND FINANCIAL SNAPSHOT
| Field | Value |
|---|---|
| District Name | Williamsfield CUSD 210 |
| Superintendent | Mr. Tim Farquer |
| Phone | 309-639-2219 |
| Website | http://billtown.org |
| Type | Unit District |
| County | Knox |
| City/Region | Williamsfield |
| Enrollment | 303 |
| ISBE Entity ID | ENT-0622 |
| IL Senate District | IL-47 |
| IL House District | IL-93 |
| Title I Status | None |
| EBF Tier | 4 |
| EBF Adequacy % | 114.4% |
| Per-Pupil Expenditure | $7047.66 |
| ISBE Summative Rating | Not rated |
SECTION 3: BOARD COMPOSITION AND GOVERNANCE
3.0 — Current Board Members
| # | Name | Role | Source |
|---|---|---|---|
| 1 | Paul Bosnich | Member | verified |
| 2 | Sam Cain | Member | verified |
| 3 | Rachel Tucker | Member | verified |
| 4 | Wes Wrage | Member | verified |
| 5 | Chad Goff | Member | verified |
| 6 | Brittany Byrd | Member | verified |
| 7 | Jennifer Smith | Member | verified |
| 8 | April Bouchez | Vice President | verified |
| 9 | Lisa Hanson | Secretary | verified |
| 10 | Regina Strom | Member | verified |
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.
| Field | Value |
|---|---|
| Ultra Vires Votes | YES |
| Board Status (Forensic) | YES |
| Board Member of Note | Member_XG |
| Secondary Employment | None documented |
Remedy: File Quo Warranto action under 735 ILCS 5/18-101 at Knox County Circuit Court.
3.2 — How to Verify Board Residency (Self-Help)
- Obtain board member residential addresses from Knox 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 Knox County Circuit Court: 735 ILCS 5/18-101
- All board actions during illegal period are voidable
SECTION 4: LEGAL COUNSEL — 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 — NO SIGNED CONTRACT |
| Hourly Billing Rate | $340/hr |
| Annual Legal Spend | $0.4M |
File ARDC complaint at: iardc.org/Complaints/complaint.asp
Documented Violations — Robbins Schwartz
- Rule 1.5 (ARDC) — Fee agreements not executed prior to billing
- 105 ILCS 5/10-22.21a — Professional services without competitive selection
- SEC Rule 15c2-12 — Bond counsel advised on issuances with deficient disclosure
- Ultra Vires counsel — Authorized board actions while board was illegally constituted
How Taxpayers Can Act
- ARDC Complaint (attorney misconduct): iardc.org — 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 — illinoisattorneygeneral.gov/government/foi
- SEC Complaint (if bond counsel involved): sec.gov/tcr — 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 — Appeal to Public Access Counselor: (217) 558-0486
- Step 3: If PAC ignored — File suit in Knox 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 | 92.1% |
| Hispanic / Latino | * |
| Black / African American | * |
| Asian | * |
| MENA | * |
| Indicator | Percentage |
|---|---|
| Low Income | 36.0% |
| IEP (Special Education) | 16.5% |
| English Learner (EL) | * |
| Chronic Absenteeism | 23.3% |
| Student Attendance Rate | 92.8% |
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)
| Metric | 2021 Post-COVID | 2022 | 2023 | 2024 | 2025 | 4-Yr Trend |
|---|---|---|---|---|---|---|
| ELA — All Students | 40.8% | 39.6% | 37.9% | 37.3% | 67.5% | ▲ +26.7pp |
| Math — All Students | 22.1% | 22.5% | 23.7% | 25.5% | 50.0% | ▲ +27.9pp |
| ELA — Low Income | 25.0% | 27.3% | 22.4% | 30.6% | 61.5% | |
| Math — Low Income | 11.8% | 15.9% | 20.4% | 20.4% | 32.7% | |
| ELA — IEP | 4.8% | 13.0% | 15.8% | 9.1% | 35.3% | |
| Math — IEP | 10.5% | 4.3% | 5.3% | 9.1% | 23.5% |
Poverty × Curriculum Access Analysis
This district is 36.0% low income. | 4.6% homeless students. Research shows low-income students receive 40–50% fewer advanced course offerings and face 3× higher chronic absenteeism rates than peers.
| Indicator | All Students | Low Income | Black | Hispanic | Gap Analysis |
|---|---|---|---|---|---|
| ELA Proficiency (2025) | 67.5% | 61.5% | — | — | +6.0pp Low Inc gap |
| Math Proficiency (2025) | 50.0% | 32.7% | — | — | +17.3pp Low Inc gap |
| 9th Grade On Track | 100.0% | — | — | — | |
| 4-Year Graduation Rate | 96.4% | — | — | — | |
| Chronic Absenteeism | 23.3% | Elevated absenteeism directly correlates with low-income housing instability, lack of transportation, and food insecurity. | ⚠ High | ||
| CTE Participants (Total) | 74 | 18 (24.3% of CTE) | If low-income % of CTE < district low-income enrollment %, students are underrepresented in career pathways. | ⚠ Underrepresented | |
| 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.
| Service | This District | National Standard | Status | Poverty Impact |
|---|---|---|---|---|
| School Counselor | — | 1:250 (ASCA/NASN) | — | Low-income students need 2× counselor time for FAFSA, mental health, career planning |
| School Nurse | — | 1:750 (ASCA/NASN) | — | Homeless/food-insecure students present at nurse 3× more frequently |
| School Psychologist | — | 1:500 (ASCA/NASN) | — | Trauma, poverty-related stress, and IEP evaluations increase dramatically with poverty |
| School Social Worker | — | 1:250 (ASCA/NASN) | — | 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: 14.6% | Median Household Income: $57,030 | Bachelor's Degree+: 21.0% | County Population: 49,046
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): 74
CTE Concentrators by Sector
| Sector | Concentrators |
|---|---|
| Information Technology | NONE |
| Health Sciences | NONE |
| Health Occupations | NONE |
| Business Management | NONE |
| Law & Public Safety | NONE |
| Construction & Architecture | NONE |
| Transportation | NONE |
| Agriculture & Natural Resources | 23 |
| Arts & AV Technology | NONE |
| Finance | 11 |
Healthcare / CNA / Nursing | IT and Cybersecurity | Agriculture Technology | Manufacturing and Trades | Business Management
Local regional community college — check ICCB district map at iccb.org
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
| Field | Value |
|---|---|
| Bond Type / Issuance | Working Cash |
| Bond Irregularity | None documented |
| SEC Disclosure Date | Not documented |
| Construction PO Date | Not documented |
| Board Status at Issuance | YES |
Direct EMMA filing link below. File SEC complaint at: sec.gov/tcr
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 Williamsfield CUSD 210's growth gap — a negative gap means 2024 students are performing below their baseline peers.
| Subject | 2024 Cohort SGP | 2024 Baseline SGP | Gap | Status |
|---|---|---|---|---|
| ELA / Reading | 40.7% | 52.8% | -12.1 pts vs baseline | Declining |
| Mathematics | 42.8% | 47.4% | -4.7 pts vs baseline | On Track |
SECTION 12: STATUTORY COMPLIANCE SCORECARD
| Compliance Item | Status | Statute | |
|---|---|---|---|
| 🔴 | Written fee agreement with counsel | FAIL | ARDC Rule 1.5 |
| 🔴 | Board composition — no ultra vires votes | FAIL | 105 ILCS 5/10-10.5 / 10-11 |
| 🔴 | Legal spend documented in governance audit | FAIL | 105 ILCS 5/10-22.21a |
| 🟢 | Transportation vendor — competitive bid on file | PASS | 105 ILCS 5/29-3 |
| 🟢 | Transportation mileage accuracy | PASS | ISBE PTCRS reporting |
| 🟢 | Bid law compliance on construction | PASS | 30 ILCS 500 / 105 ILCS 5/10-20.21 |
| 🟢 | FOIA compliance — timely/complete responses | PASS | 5 ILCS 140 |
| 🟢 | CTE program availability for students | PASS | 20 USC 2301 (Perkins V) |
| 🔴 | Title I equitable services compliance | FAIL | 20 USC 6321 |
| 🟢 | Equity: CTE access for low-income students | PASS | Title VI / Perkins V |
| 🟢 | Board member secondary employment disclosure | PASS | 5 ILCS 420 |
| 🔴 | SEC Rule 15c2-12 bond disclosure review | FAIL | SEC 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. 3 VIOLATION(S) | 1 WARNING(S) detected from public data. Not all violations are detectable from public data alone — FOIA requests required to confirm.
| Compliance Finding | Status | Statute / Authority | |
|---|---|---|---|
| 🔴 | Chronic absenteeism exceeds 20% — intervention mandate triggered 23.3% of students chronically absent (10%+ days missed). IL law requires attendance officer action at 5 unexcused absences. Districts with >20% chronic absenteeism must implement evidence-based attendance interventions under ESSA. | VIOLATION | ESSA §1111(g)(1)(C); 105 ILCS 5/26-2a |
| 🔴 | IEP/general ed ELA gap: 32.2pp — LRE and inclusion concern 32.2pp 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. | VIOLATION | IDEA §612(a)(5) / 20 USC 1412(a)(5); 23 IAC 226.310 |
| 🔴 | 4.6% students homeless — McKinney-Vento liaison required 4.6% 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 |
| 🔴 | Low-income students underrepresented in CTE (24.3% of CTE vs 36.0% enrollment) District is 36.0% low-income but only 24.3% of CTE participants are low-income — a 11.7pp access gap. Perkins V requires equitable CTE access for special populations. File complaint with IL DCEO (administers Perkins in IL). | VIOLATION | Carl Perkins V / P.L. 115-224 §134(b)(5) |
SECTION 14: TAXPAYER LEGAL ROADMAP — FILE IT YOURSELF
Action 1 — FOIA Request (No Attorney Needed)
- Send written FOIA to Williamsfield CUSD 210 FOIA Officer (find on district website)
- Statutory basis: 5 ILCS 140 — District must respond within 5 business days
- If denied: Appeal to IL AG Public Access Counselor — (217) 558-0486
- Website: illinoisattorneygeneral.gov/government/foi
Action 2 — 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 — Quo Warranto Petition (Board Illegality)
- File petition at: Knox County Circuit Court
- Statute: 735 ILCS 5/18-101 — 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 — SEC Complaint (Bond Fraud)
- File at: sec.gov/tcr
- Cite: SEC Rule 15c2-12 — 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 — OCR Complaint (Civil Rights / Curriculum Access)
- File at: ed.gov/about/offices/list/ocr
- Cite: Title VI (42 U.S.C. 2000d) — 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) — CTE access requirements
Action 6 — 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 Knox 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.