Every now and then, we come across “uncitable” orders filed pursuant to Illinois Supreme Court Rule 23(e), that deal with fundamental Chicago Residential Landlord Tenant Ordinance (RLTO) security deposit issues. These are strange birds. They are “out there” in the stream of discourse, however, they cannot be cited (except in rare exceptions) and have no precedential value. Depending on your perspective, this might or might not be a good thing.
