Ray Schools-Chicago-Inc. v. Cummins

Claims for unemployment benefits filed by three former employees of appellee, The Ray Schools-Chicago-Inc., a nonprofit corporation
organized under the laws of Illinois, provoked the question of whether, for the calendar year 1950, appellee was a corporation
operated exclusively for educational purposes, no part of whose net profits inured to the benefit of any private shareholder
or individual, so as to exempt it from making employer contributions under the Unemployment Compensation Act. (See: Ill. Rev.
Stat. 1949, chap. 48, par. 218(f) (6) (A) (5) (G).) Deputies for the Division of Unemployment Compensation found the claimants
were eligible for benefits, and appellee appealed to the hearings referee of the Department of Labor on the ground that money
earned in its employ in 1950 did not qualify one for benefits, inasmuch as employment in its service was exempt under the
statute. The referee concluded appellee was operated exclusively for educational purposes but denied exemption because its
operation failed to satisfy the further requirement of the statute that no part of its net earnings inure to the benefit of
any private shareholder or individual. The department's board of review affirmed such finding, whereupon appellee filed a
complaint for administrative review in the circuit court of Cook County joining the Director of Labor as a party defendant.
The circuit court reversed the administrative decision and this direct appeal for further review has been brought by the director,
the board of review, and the benefit claimants. We are first met with the question of whether appellee is an institution operated exclusively for educational purposes within
the meaning of the exemption provision of the Unemployment Compensation Act. The trial court refused to pass upon the merits
of such issue, indicating, by means of a written opinion, his belief that the finding of the board of review was perhaps binding
on appellants and that he considered a decision rendered by a Federal bankruptcy referree in 1944 to be res judicata or estoppel
by judgment on the question of appellee's exemption. Inasmuch as we have held that an erroneous construction of a statute
by an administrative agency is not binding on the courts, (Baptista Films v. Cummins, 9 Ill.2d 259, 265; Winakor v. Annunzio,
409 Ill. 236, 248,) the board's construction that appellee is an educational institution is no barrier to our further construction
of the statute. However, whether the doctrines of res judicata and collateral estoppel should operate to deny the present
benefit claimants their day in court, and to foreclose our authority to construe the statutes of this State, is not so readily
concluded.