FORENSIC AUDIT REPORT — WILLIAMSFIELD CUSD 210

Williamsfield, Knox County, Illinois | Unit District | Entity: ENT-0622
Enrollment: 303Counsel: Robbins SchwartzULTRA VIRES BOARDEst. Waste: $0Senate: IL-47 | House: IL-93
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EXECUTIVE SUMMARY

This is a public record forensic audit of Williamsfield CUSD 210. 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
YES
Counsel Contract
YES — NO SIGNED CONTRACT
Annual Legal Spend
$0.4M
EBF Funding Tier
Tier 4 (114.4%)
ISBE Summative Rating
Not rated

Priority Findings

SECTION 1: DISTRICT PROFILE AND FINANCIAL SNAPSHOT

FieldValue
District NameWilliamsfield CUSD 210
SuperintendentMr. Tim Farquer
Phone309-639-2219
Websitehttp://billtown.org
TypeUnit District
CountyKnox
City/RegionWilliamsfield
Enrollment303
ISBE Entity IDENT-0622
IL Senate DistrictIL-47
IL House DistrictIL-93
Title I StatusNone
EBF Tier4
EBF Adequacy %114.4%
Per-Pupil Expenditure$7047.66
ISBE Summative RatingNot rated
EBF Adequacy
114.4%
Adequately funded
EBF Tier 4: This district is receiving full funding.

SECTION 3: BOARD COMPOSITION AND GOVERNANCE

3.0 — Current Board Members

#NameRoleSource
1Paul BosnichMemberverified
2Sam CainMemberverified
3Rachel TuckerMemberverified
4Wes WrageMemberverified
5Chad GoffMemberverified
6Brittany ByrdMemberverified
7Jennifer SmithMemberverified
8April BouchezVice Presidentverified
9Lisa HansonSecretaryverified
10Regina StromMemberverified

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 VotesYES
Board Status (Forensic)YES
Board Member of NoteMember_XG
Secondary EmploymentNone documented
ULTRA VIRES FINDING: This board has documented ultra vires votes — actions taken beyond legal authority. These actions are voidable. Bond issuances, contracts, and policy changes during this period are subject to legal challenge.

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)

SECTION 4: LEGAL COUNSEL — ROBBINS SCHWARTZ

FieldValue
Counsel of RecordRobbins Schwartz
Address55 W. Monroe St., Suite 800, Chicago, IL 60603 | (312) 332-7760
Fee Agreement StatusYES — NO SIGNED CONTRACT
Hourly Billing Rate$340/hr
Annual Legal Spend$0.4M
NO SIGNED FEE AGREEMENT: This district is paying Robbins Schwartz without a written engagement letter — a direct violation of ARDC Rule 1.5. Every dollar billed without a signed contract is potentially a disciplinary matter.

File ARDC complaint at: iardc.org/Complaints/complaint.asp

Documented Violations — Robbins Schwartz

How Taxpayers Can Act

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

To: FOIA Officer, Williamsfield CUSD 210 Request 1 — LEGAL FEES: All executed fee agreements with Robbins Schwartz or any law firm, FY2015-present. All legal invoices paid to Robbins Schwartz, 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: 39.6% → 67.9% ▲ +28.3%  |  Math: 22.5% → 46.3% ▲ +23.8%
303
Per-Pupil Expenditure
$7047.66
EBF Adequacy
114.4%
Annual Legal Spend
$0.4M
Hourly Legal Rate
$340/hr
Est. Total Waste
$0
ELA Proficiency
67.9%
Math Proficiency
46.3%
4-Year Grad Rate
96.4%
9th Grade On Track
100.0%

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
White92.1%
Hispanic / Latino*
Black / African American*
Asian*
MENA*
IndicatorPercentage
Low Income36.0%
IEP (Special Education)16.5%
English Learner (EL)*
Chronic Absenteeism23.3%
Student Attendance Rate92.8%
Demographic to Curriculum Gap: A district that is 36.0% low-income and *% Hispanic with 74 CTE concentrators is providing some CTE access — see sector gaps below.
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 Students40.8%39.6%37.9%37.3%67.5%▲ +26.7pp
Math — All Students22.1%22.5%23.7%25.5%50.0%▲ +27.9pp
ELA — Low Income25.0%27.3%22.4%30.6%61.5%
Math — Low Income11.8%15.9%20.4%20.4%32.7%
ELA — IEP4.8%13.0%15.8%9.1%35.3%
Math — IEP10.5%4.3%5.3%9.1%23.5%
+6.0pp ELA Low Income gap vs All (2025)+32.2pp ELA IEP gap vs All (2025)+17.3pp Math Low Income gap vs All (2025)+26.5pp Math IEP gap vs All (2025)

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.

IndicatorAll StudentsLow IncomeBlackHispanicGap 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.

ServiceThis DistrictNational StandardStatusPoverty Impact
School Counselor1:250 (ASCA/NASN)Low-income students need 2× counselor time for FAFSA, mental health, career planning
School Nurse1:750 (ASCA/NASN)Homeless/food-insecure students present at nurse 3× more frequently
School Psychologist1:500 (ASCA/NASN)Trauma, poverty-related stress, and IEP evaluations increase dramatically with poverty
School Social Worker1:250 (ASCA/NASN)Social workers are the primary poverty-intervention link between school and family
Why this matters: A district that is 36.0% low income with a 1:? 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: $20,763  |  EBF Adequacy: 120.0% (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.
📍 Knox County Economic Context (ACS 2024):
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

SectorConcentrators
Information TechnologyNONE
Health SciencesNONE
Health OccupationsNONE
Business ManagementNONE
Law & Public SafetyNONE
Construction & ArchitectureNONE
TransportationNONE
Agriculture & Natural Resources23
Arts & AV TechnologyNONE
Finance11
No specific access gap documented. Review CTE concentrator data by race/income for equity gaps.
What this district should offer (based on demographics):
Healthcare / CNA / Nursing | IT and Cybersecurity | Agriculture Technology | Manufacturing and Trades | Business Management
Nearest Community College Partners:
Local regional community college — check ICCB district map at iccb.org

How to Force Dual Credit Expansion

SECTION 10: BOND ISSUANCE AND DEBT

FieldValue
Bond Type / IssuanceWorking Cash
Bond IrregularityNone documented
SEC Disclosure DateNot documented
Construction PO DateNot documented
Board Status at IssuanceYES
SEC Rule 15c2-12: Requires school districts issuing bonds to file continuing disclosure reports on MSRB EMMA (emma.msrb.org). Failure to disclose material events is a federal securities violation.
Direct EMMA filing link below. File SEC complaint at: sec.gov/tcr
No active bonds found in MSRB registry for this district. May operate on local tax levy only, or bonds may be under a different legal entity name.
📄 Search 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 Williamsfield CUSD 210's growth gap — a negative gap means 2024 students are performing below their baseline peers.

ELA Growth vs Baseline (2024)
▼ -12.1 pts
2024 Cohort: 40.7% | Baseline: 52.8%
Math Growth vs Baseline (2024)
▼ -4.7 pts
2024 Cohort: 42.8% | Baseline: 47.4%
Subject2024 Cohort SGP2024 Baseline SGPGapStatus
ELA / Reading40.7%52.8%-12.1 pts vs baselineDeclining
Mathematics42.8%47.4%-4.7 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 counselFAILARDC Rule 1.5
🔴Board composition — no ultra vires votesFAIL105 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 studentsPASS20 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. 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 FindingStatusStatute / 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.
VIOLATIONESSA §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.
VIOLATIONIDEA §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 REQUIREDMcKinney-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).
VIOLATIONCarl Perkins V / P.L. 115-224 §134(b)(5)
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 Knox County. Your filing court is the Knox 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.