Case: 1:15-cv-00444 Document #: 24 Filed: 05/08/15 Page 1 of 3 PageID #:212
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ILLINOIS BIBLE COLLEGES ASSOCIATION, et al., Plaintiffs, v. LINDSAY K. H. ANDERSON, Chair of the Illinois Board of Higher Education, Defendant.
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No. 15 C 444 Judge Sharon Johnson Coleman
MOTION TO DISMISS The defendant, Lindsay K. H. Anderson, by her attorney, Lisa Madigan, Attorney General of Illinois, moves the Court, pursuant to Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure, to dismiss the First Amended Complaint for lack of subject matter jurisdiction (as to some claims) and for failure to state a claim upon which relief can be granted. In support of this motion, defendant states as follows: 1. Plaintiffs are a number of Bible colleges, an association of Bible colleges, a student at a Bible college, and an organization supporting the claims of the Bible colleges. Plaintiffs challenge several Illinois statutes, the Private College Act, 110 ILCS 1005/0.01 et seq., and the Academic Degree Act, 110 ILCS 1010/0.01 et seq., both of which regulate the operations of certain postsecondary educational institutions, and the Private Business and Vocational Schools Act, 105 ILCS 426/1 et seq., which regulates the operations of business and vocational schools. 2. These statutes are administered by the Illinois Board of Higher Education, whose Chair,
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