{ "id": 3716297, "name": "MICHAEL A. RAJTEROWSKI et al., Plaintiffs-Appellants, v. THE CITY OF SYCAMORE et al., Defendants-Appellees", "name_abbreviation": "Rajterowski v. City of Sycamore", "decision_date": "2010-11-01", "docket_number": "No. 2\u201409\u20141136", "first_page": "1086", "last_page": "1123", "citations": [ { "type": "official", "cite": "405 Ill. App. 3d 1086" } ], "court": { "name_abbreviation": "Ill. App. Ct.", "id": 8837, "name": "Illinois Appellate Court" }, "jurisdiction": { "id": 29, "name_long": "Illinois", "name": "Ill." }, "cites_to": [ { "cite": "222 Ill. 2d 276", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3602377 ], "year": 2006, "pin_cites": [ { "page": "283", "parenthetical": "Attorney General's well-reasoned opinions \"interpreting or construing an Illinois statute are persuasive authority and are entitled to considerable weight in resolving a question of first impression, although they do not have the force and effect of law\"" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/222/0276-01" ] }, { "cite": "505 U.S. 1", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 1481159 ], "weight": 6, "year": 1992, "pin_cites": [ { "page": "12" }, { "page": "13" }, { "page": "2333" } ], "opinion_index": 0, "case_paths": [ "/us/505/0001-01" ] }, { "cite": "294 Ill. App. 3d 868", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 35446 ], "weight": 2, "year": 1998, "pin_cites": [ { "page": "870" }, { "page": "870" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/294/0868-01" ] }, { "cite": "207 Ill. App. 3d 1053", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 2554060 ], "weight": 2, "year": 1991, "pin_cites": [ { "page": "1059" }, { "page": "1059" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/207/1053-01" ] }, { "cite": "288 Ill. App. 3d 373", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 1596950 ], "year": 1997, "pin_cites": [ { "page": "380" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/288/0373-01" ] }, { "cite": "17 Ill. 2d 277", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5333069 ], "year": 1959, "pin_cites": [ { "page": "285" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/17/0277-01" ] }, { "cite": "76 Ill. 2d 469", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 2984705 ], "weight": 6, "year": 1979, "pin_cites": [ { "page": "476" }, { "page": "476-77" }, { "page": "476-77" }, { "page": "477" }, { "page": "477" }, { "page": "477" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/76/0469-01" ] }, { "cite": "329 Ill. App. 3d 781", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 1472358 ], "weight": 2, "year": 2002, "pin_cites": [ { "page": "798" }, { "page": "798" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/329/0781-01" ] }, { "cite": "172 Ill. 2d 243", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 55980 ], "year": 1996, "pin_cites": [ { "page": "250" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/172/0243-01" ] }, { "cite": "117 Ill. 2d 454", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5545454 ], "year": 1987, "pin_cites": [ { "page": "467" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/117/0454-01" ] }, { "cite": "153 Ill. 2d 239", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 4739021 ], "weight": 4, "year": 1992, "pin_cites": [ { "page": "248" }, { "page": "248" }, { "page": "249" }, { "page": "252" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/153/0239-01" ] }, { "cite": "357 Ill. App. 3d 905", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 4135119 ], "weight": 4, "year": 2005, "pin_cites": [ { "page": "914" }, { "page": "914" }, { "page": "914" }, { "page": "914" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/357/0905-01" ] }, { "cite": "427 U.S. 297", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6176137 ], "weight": 3, "year": 1976, "pin_cites": [ { "page": "303" }, { "page": "517", "parenthetical": "\"States are accorded wide latitude in the regulation of their local economies under their police powers, and rational distinctions may be made with substantially less than mathematical exactitude. Legislatures may implement their program step by step\"" }, { "page": "2517", "parenthetical": "\"States are accorded wide latitude in the regulation of their local economies under their police powers, and rational distinctions may be made with substantially less than mathematical exactitude. Legislatures may implement their program step by step\"" } ], "opinion_index": 0, "case_paths": [ "/us/427/0297-01" ] }, { "cite": "281 Ill. App. 3d 679", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 150147 ], "weight": 7, "year": 1996, "pin_cites": [ { "page": "683-85" }, { "page": "683" }, { "page": "685" }, { "page": "685" }, { "page": "685" }, { "page": "684" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/281/0679-01" ] }, { "cite": "837 N.E.2d 662", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2005, "pin_cites": [ { "page": "667-68" } ], "opinion_index": 0 }, { "cite": "445 Mass. 304", "category": "reporters:state", "reporter": "Mass.", "case_ids": [ 2824241 ], "year": 2005, "pin_cites": [ { "page": "311" } ], "opinion_index": 0, "case_paths": [ "/mass/445/0304-01" ] }, { "cite": "419 U.S. 393", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6175706 ], "weight": 3, "year": 1975, "pin_cites": [ { "page": "406-09" }, { "page": "544-46" }, { "page": "561-62" } ], "opinion_index": 0, "case_paths": [ "/us/419/0393-01" ] }, { "cite": "457 U.S. 55", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6184530 ], "weight": 9, "year": 1982, "pin_cites": [ { "page": "60-64" }, { "page": "677-80" }, { "page": "2313-15" }, { "page": "60-64" }, { "page": "677-80" }, { "page": "2313-15" }, { "page": "59" }, { "page": "677" }, { "page": "2312" } ], "opinion_index": 0, "case_paths": [ "/us/457/0055-01" ] }, { "cite": "472 U.S. 612", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 1512478 ], "weight": 27, "year": 1985, "pin_cites": [ { "page": "618" }, { "page": "493" }, { "page": "2866" }, { "page": "619" }, { "page": "494" }, { "page": "2866-67" }, { "page": "620-21" }, { "page": "494-95" }, { "page": "2867-68" }, { "page": "623" }, { "page": "496" }, { "page": "2868" }, { "page": "623" }, { "page": "497" }, { "page": "2869" }, { "page": "623" }, { "page": "497" }, { "page": "2869" }, { "page": "618" }, { "page": "493" }, { "page": "2862" }, { "page": "623" }, { "page": "496" }, { "page": "2869" } ], "opinion_index": 0, "case_paths": [ "/us/472/0612-01" ] }, { "cite": "476 U.S. 898", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 12880 ], "weight": 15, "year": 1986, "pin_cites": [ { "page": "911" }, { "page": "911" }, { "page": "2325" }, { "page": "906" }, { "page": "907" }, { "page": "2322" }, { "page": "908" }, { "page": "909" }, { "page": "2324" }, { "page": "909" }, { "page": "909" }, { "page": "2324" }, { "page": "909" }, { "page": "909" }, { "page": "2324" } ], "opinion_index": 0, "case_paths": [ "/us/476/0898-01" ] }, { "cite": "405 U.S. 330", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 11722480 ], "weight": 3, "year": 1972, "pin_cites": [ { "page": "338" }, { "page": "281-82", "parenthetical": "applying strict-scrutiny analysis to invalidate, as violative of rights to travel and vote, Tennessee durational residency law that required a voter to be a resident of the state for one year and of the county for three months before the voter could vote" }, { "page": "1001", "parenthetical": "applying strict-scrutiny analysis to invalidate, as violative of rights to travel and vote, Tennessee durational residency law that required a voter to be a resident of the state for one year and of the county for three months before the voter could vote" } ], "opinion_index": 0, "case_paths": [ "/us/405/0330-01" ] }, { "cite": "415 U.S. 250", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6174206 ], "weight": 3, "year": 1974, "pin_cites": [ { "page": "259" }, { "page": "315" }, { "page": "1082-83" } ], "opinion_index": 0, "case_paths": [ "/us/415/0250-01" ] }, { "cite": "415 U.S. 651", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6179827 ], "weight": 6, "year": 1974, "opinion_index": 0, "case_paths": [ "/us/415/0651-01" ] }, { "cite": "394 U.S. 618", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6177874 ], "weight": 6, "year": 1969, "pin_cites": [ { "page": "634", "parenthetical": "applying strict-scrutiny review and holding invalid as a restriction on the fundamental right to travel a one-year residency requirement for subsistence welfare benefits" }, { "page": "615", "parenthetical": "applying strict-scrutiny review and holding invalid as a restriction on the fundamental right to travel a one-year residency requirement for subsistence welfare benefits" }, { "page": "1331", "parenthetical": "applying strict-scrutiny review and holding invalid as a restriction on the fundamental right to travel a one-year residency requirement for subsistence welfare benefits" }, { "parenthetical": "citing cases" }, { "parenthetical": "citing cases" }, { "parenthetical": "citing cases" } ], "opinion_index": 0, "case_paths": [ "/us/394/0618-01" ] }, { "cite": "405 U.S. 56", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 11721238 ], "weight": 3, "year": 1972, "pin_cites": [ { "page": "74" }, { "page": "51" }, { "page": "874" } ], "opinion_index": 0, "case_paths": [ "/us/405/0056-01" ] }, { "cite": "416 U.S. 1", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 84266 ], "weight": 3, "year": 1974, "pin_cites": [ { "page": "7-9" }, { "page": "803-04" }, { "page": "1540-41" } ], "opinion_index": 0, "case_paths": [ "/us/416/0001-01" ] }, { "cite": "171 Ill. 2d 510", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 57345 ], "year": 1996, "pin_cites": [ { "page": "521" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/171/0510-01" ] }, { "cite": "189 Ill. 2d 548", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 1224797 ], "weight": 2, "year": 2000, "pin_cites": [ { "page": "561-62" }, { "page": "562" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/189/0548-01" ] }, { "cite": "362 Ill. App. 3d 716", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 4260043 ], "year": 2005, "pin_cites": [ { "page": "720" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/362/0716-01" ] }, { "cite": "82 Ill. 2d 116", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5475431 ], "weight": 3, "year": 1980, "pin_cites": [ { "page": "119-20" }, { "page": "120" }, { "page": "121", "parenthetical": "the Supreme Court \"has clearly ruled that a right to private housing is not a fundamental right\" and, thus, applies rational-basis review \"to government actions that might burden a person's ability to find adequate housing\"" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/82/0116-01" ] }, { "cite": "68 Ill. 2d 88", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5809786 ], "year": 1977, "pin_cites": [ { "page": "97" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/68/0088-01" ] }, { "cite": "451 U.S. 648", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6190926 ], "weight": 3, "year": 1981, "pin_cites": [ { "page": "656-57" }, { "page": "523" }, { "page": "2077" } ], "opinion_index": 0, "case_paths": [ "/us/451/0648-01" ] }, { "cite": "102 Ill. 2d 295", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3156535 ], "year": 1984, "pin_cites": [ { "page": "299" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/102/0295-01" ] }, { "cite": "437 U.S. 518", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6182058 ], "weight": 3, "year": 1978, "pin_cites": [ { "page": "525-27" }, { "page": "404-05" }, { "page": "2487-88" } ], "opinion_index": 0, "case_paths": [ "/us/437/0518-01" ] }, { "cite": "81 S.D. 629", "category": "reporters:state", "reporter": "S.D.", "case_ids": [ 4627172 ], "weight": 2, "year": 1966, "pin_cites": [ { "page": "632", "parenthetical": "advisory opinion holding that property tax relief act that granted to South Dakota residents a real estate tax refund not allowed to nonresidents was unconstitutional as violating privileges and immunities clause" }, { "page": "35", "parenthetical": "advisory opinion holding that property tax relief act that granted to South Dakota residents a real estate tax refund not allowed to nonresidents was unconstitutional as violating privileges and immunities clause" } ], "opinion_index": 0, "case_paths": [ "/sd/81/0629-01" ] }, { "cite": "146 N.W.2d 306", "category": "reporters:state_regional", "reporter": "N.W.2d", "year": 1966, "pin_cites": [ { "page": "314", "parenthetical": "statute denying nonresident Iowa landowners a land tax credit that was granted to resident owners held unconstitutional as violating the privileges and immunities clause" } ], "opinion_index": 0 }, { "cite": "259 Iowa 808", "category": "reporters:state", "reporter": "Iowa", "case_ids": [ 4399190 ], "year": 1966, "pin_cites": [ { "page": "819", "parenthetical": "statute denying nonresident Iowa landowners a land tax credit that was granted to resident owners held unconstitutional as violating the privileges and immunities clause" } ], "opinion_index": 0, "case_paths": [ "/iowa/259/0808-01" ] }, { "cite": "20 L. Ed. 449", "category": "reporters:federal", "reporter": "L. Ed.", "case_ids": [ 5655323 ], "year": 1871, "pin_cites": [ { "page": "452" } ], "opinion_index": 0, "case_paths": [ "/us/79/0418-01" ] }, { "cite": "526 U.S. 489", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 11133435 ], "weight": 9, "year": 1999, "pin_cites": [ { "page": "500-01", "parenthetical": "discussing the three aspects of the right to travel and noting that the privileges and immunities clause of article IV protects citizens of one state who travel to another state, intending to return home at the end of their journey" }, { "page": "702", "parenthetical": "discussing the three aspects of the right to travel and noting that the privileges and immunities clause of article IV protects citizens of one state who travel to another state, intending to return home at the end of their journey" }, { "page": "1525", "parenthetical": "discussing the three aspects of the right to travel and noting that the privileges and immunities clause of article IV protects citizens of one state who travel to another state, intending to return home at the end of their journey" }, { "page": "502-03" }, { "page": "703-04" }, { "page": "1526" }, { "page": "500-01" }, { "page": "702" }, { "page": "1525" } ], "opinion_index": 0, "case_paths": [ "/us/526/0489-01" ] }, { "cite": "92 L. Ed. 1460", "category": "reporters:federal", "reporter": "L. Ed.", "year": 1948, "pin_cites": [ { "page": "1475" } ], "opinion_index": 0 }, { "cite": "334 U.S. 385", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6158252 ], "weight": 2, "year": 1948, "pin_cites": [ { "page": "403" }, { "page": "1165" } ], "opinion_index": 0, "case_paths": [ "/us/334/0385-01" ] }, { "cite": "410 U.S. 179", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 11957079 ], "weight": 3, "year": 1973, "pin_cites": [ { "page": "200" }, { "page": "217" }, { "page": "751" } ], "opinion_index": 0, "case_paths": [ "/us/410/0179-01" ] }, { "cite": "436 U.S. 371", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 1490425 ], "weight": 15, "year": 1978, "pin_cites": [ { "page": "387" }, { "page": "367" }, { "page": "1862" }, { "page": "383" }, { "page": "365" }, { "page": "1860" }, { "page": "383" }, { "page": "365" }, { "page": "1860" }, { "page": "388" }, { "page": "368" }, { "page": "1863" }, { "page": "383" }, { "page": "365" }, { "page": "1860" } ], "opinion_index": 0, "case_paths": [ "/us/436/0371-01" ] }, { "cite": "131 Ill. 2d 79", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5570320 ], "year": 1989, "pin_cites": [ { "page": "88", "parenthetical": "\"clause prohibits one State from discriminating against citizens of another State\" and \"does not apply where a city or municipal ordinance discriminates against intrastate residents\" (emphasis added)" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/131/0079-01" ] }, { "cite": "19 L. 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RAJTEROWSKI et al., Plaintiffs-Appellants, v. THE CITY OF SYCAMORE et al., Defendants-Appellees." ], "opinions": [ { "text": "JUSTICE JORGENSEN\ndelivered the opinion of the court:\nIn an amended five-count complaint, plaintiffs, Michael A. Rajterowski, Robert and Lynn Skelton, Michelle and Jeffrey Eliason, and Paul Brian and Andrea Lee Hudon, sued defendants, the City of Sycamore (City) and Sycamore Community Unit School District No. 427 (School District), arguing that the City\u2019s real estate transfer tax, from which buyers of homestead real estate who had resided in the City for at least one year were exempt, violated the federal and state constitutions and that, in entering into an intergovernmental agreement under which the City forwarded transfer tax revenues to the School District, the City and the School District exceeded their constitutional and statutory authority. Defendants moved to dismiss plaintiffs\u2019 complaint, asserting that it failed to state a cause of action. 735 ILCS 5/2 \u2014 615 (West 2008). The trial court granted defendants\u2019 motion as to all counts and dismissed plaintiffs\u2019 complaint with prejudice. Plaintiffs appeal. We affirm.\nI. BACKGROUND\nOn March 21, 2006, a referendum was passed, authorizing the City, a home rule municipality, to impose a municipal transfer tax on real property transferred within its boundaries (Transfer Tax). On April 17, 2006, the City adopted Ordinance No. 2005.93 (Ordinance), which established the Transfer Tax. The Ordinance became effective on June 1, 2006, and imposed on the transfer of title to real estate located in the City a tax at a rate of $5 for each $1,000 of value or fraction thereof.\nThe Ordinance was intended by the City to create a new source of funds that it would give to the School District, a public school district, to supplement the School District\u2019s operating revenue. The mechanism by which the City provides the funds to the School District is an intergovernmental agreement (Intergovernmental Agreement) executed pursuant to the Illinois Intergovernmental Cooperation Act (5 ILCS 220/1 et seq. (West 2008)). The agreement provided that certain start-up and ongoing operating expenses the City incurred that were related to the Transfer Tax would be withheld from the revenues generated by the tax. There would also be a cooperatively established method to account for the monies received from the Transfer Tax and distributed to the School District.\nThe Ordinance contains an exemption, which is at issue in this appeal, for buyers of homestead real estate within the City who have been residents of the City for at least one year:\n\u201c1. The following deeds shall be exempt from the tax levied by this Article:\n* * *\n(n) A deed or trust document where the grantee or buyer is purchasing homestead real estate within the [Cjity and has maintained resident status (whether as a tenant or as an owner-occupier of real property) within the corporate limits of the City *** for a period of at least one year immediately prior to the date of application for exemption from the transfer tax to be imposed.\u201d Sycamore Municipal Code \u00a73 \u2014 20\u20146 (2006).\nRajterowski formerly lived one-quarter mile outside the City\u2019s limits and purchased a home in the City in July 2006. Robert and Lynn Skelton formerly lived in Edwardsville and purchased a home in the City in October 2006. Michelle and Jeffrey Eliason formerly resided in Texas and purchased a home in the City in June 2006. Paul and Andrea Hudon formerly resided in Florida and purchased a home in the City in August 2006. Because plaintiffs had not been residents of the City for one year immediately prior to purchasing homestead property in the City they did not qualify for the Transfer Tax exemption. Plaintiffs paid the Transfer Tax.\nOn July 10, 2008, plaintiffs sued the City and the School District. In a five-count complaint, plaintiffs alleged that the Transfer Tax violates the United States and Illinois Constitutions and that, in entering into the Intergovernmental Agreement, the City and the School District exceeded their authority. Specifically, plaintiffs alleged that: (1) the Ordinance violates the privileges and immunities clause of article iy section 2, of the United States Constitution (U.S. Const., art. I\\( \u00a72) (count I); (2) the Ordinance violates the equal protection clause of the United States Constitution (U.S. Const, amend. XIV) (count II); (3) the Ordinance violates the uniformity clause of the Illinois Constitution (111. Const. 1970, art. IX, \u00a72) (count III); (4) in enacting the Ordinance and entering into the Intergovernmental Agreement, the City exceeded its authority under the Illinois Constitution (count IV); and (5) in entering into the Intergovernmental Agreement, the School District exceeded its authority under the Illinois Constitution (count V).\nOn September 2, 2008, defendants moved to dismiss plaintiffs\u2019 complaint (735 ILCS 5/2 \u2014 615 (West 2008)), alleging that it failed to state any cause of action. On November 25, 2008, the court held a hearing on the motion. On January 13, 2009, the court granted the motion, finding that plaintiffs\u2019 complaint failed to state a cause of action as to all counts. The court granted plaintiffs leave to file an amended complaint.\nOn February 10, 2009, plaintiffs filed an amended 26-page, 5-count complaint. Thereafter, on March 12, 2009, defendants moved to strike and dismiss the amended complaint. On April 17, 2009, defendants moved for sanctions (155 Ill. 2d R. 137), arguing that plaintiffs\u2019 amended complaint contained no substantive changes from the initial complaint and, therefore, was an improper attempt to relitigate claims already decided by the trial court. A hearing on the motion to dismiss was held on August 20, 2009. On October 15, 2009, the trial court granted defendants\u2019 motion and dismissed plaintiffs\u2019 complaint with prejudice. Also, the court denied defendants\u2019 motion for sanctions, finding that sanctions were \u201cnot appropriate in this matter.\u201d Plaintiffs appeal.\nII. STANDARD OF REVIEW\nA motion to dismiss pursuant to section 2 \u2014 615 of the Code of Civil Procedure (735 ILCS 5/2 \u2014 615 (West 2008)) challenges only the complaint\u2019s legal sufficiency. Napleton v. Village of Hinsdale, 229 Ill. 2d 296, 305 (2008); DeWoskin v. Loew\u2019s Chicago Cinema, Inc., 306 Ill. App. 3d 504, 513 (1999) (legal sufficiency of complaint alleging constitutional violations may be raised by section 2 \u2014 615 motion). The motion does not raise affirmative factual defenses. DeWoskin, 306 Ill. App. 3d at 514. In ruling on a section 2 \u2014 615 motion to dismiss, a court should inquire whether the allegations of the complaint, when accepted as true and considered in the light most favorable to the plaintiff, are sufficient to state a cause of action upon which relief may be granted. Turner v. Memorial Medical Center, 233 Ill. 2d 494, 499 (2009). \u201cEvidentiary material outside of the complaint may not be considered.\u201d DeWoskin, 306 Ill. App. 3d at 514. Since Illinois is a fact-pleading jurisdiction, \u201ca plaintiff must allege facts sufficient to bring his or her claim within the scope of the cause of action asserted.\u201d Turner, 233 Ill. 2d at 499. A plaintiff need not prove his or her case at the pleading stage; however, he or she must allege specific facts supporting each element of the cause of action, and \u201cthe court will not admit conclusions of law and conclusory allegations not supported by specific facts.\u201d Visvardis v. Eric R Ferleger, P.C., 375 Ill. App. 3d 719, 724 (2007). A complaint should not be dismissed under section 2 \u2014 615 unless no set of facts can be proved that would entitle the plaintiff to recover. Napleton, 229 Ill. 2d at 305. We review de nova the trial court\u2019s dismissal of a complaint under section 2 \u2014 615. Kelley v. Carbone, 361 Ill. App. 3d 477, 480 (2005).\nIII. ANALYSIS\nHome rule municipalities, such as the City, have the right to levy taxes. Ill. Const. 1970, art. VII, \u00a76(a). They may exercise their taxation powers, unless restricted by the constitution or appropriate legislation. Mulligan v. Dunne, 61 Ill. 2d 544, 550 (1975). A transfer tax in and of itself does not \u201coffend any constitutional provisions.\u201d Stahl v. Village of Hoffman Estates, 296 Ill. App. 3d 550, 554 (1998); see also 65 ILCS 5/8 \u2014 3\u201419 (West 2006) (authorizing home rule municipalities to impose, upon prior approval by referendum, real estate transfer taxes). Indeed, the central issue in this case is whether plaintiffs\u2019 complaint stated a cause of action that the exemption violates certain constitutional or statutory provisions.\nA. Count I \u2014 Privileges and Immunities Clause of Article IV of the Federal Constitution\nThe privileges and immunities clause provides that: \u201cThe Citizens of each State shall be entitled to all Privileges and Immunities of Citizens in the several States.\u201d U.S. Const., art. IV \u00a72, cl. 1. It \u201cwas designed \u2018to place the citizens of each State upon the same footing with citizens of other States, so far as the advantages resulting from citizenship in those States are concerned.\u2019 \u201d United Building & Construction Trades Council v. Mayor & Council of the City of Camden, 465 U.S. 208, 215-16, 79 L. Ed. 2d 249, 257, 104 S. Ct. 1020, 1026 (1984), quoting Paul v. Virginia, 75 U.S. (8 Wall.) 168, 180, 19 L. Ed. 357, 360 (1868); see also Broeckl v. Chicago Park District, 131 Ill. 2d 79, 88 (1989) (\u201cclause prohibits one State from discriminating against citizens of another State\u201d and \u201cdoes not apply where a city or municipal ordinance discriminates against intrastate residents\u201d (emphasis added)). Although the clause is written in terms of state citizenship guarantees, it also applies to residency or citizenship restrictions established by municipalities. United Building & Construction Trades Council, 465 U.S. at 215, 79 L. Ed. 2d at 256, 104 S. Ct. at 1026. Further, merely because an ordinance disadvantages some in-state residents does not immunize the ordinance from constitutional review. United Building & Construction Trades Council, 465 U.S. at 215, 79 L. Ed. 2d at 256, 104 S. Ct. at 1026.\nIn count I of their amended complaint, the Eliasons and the Hudons (the plaintiffs who moved to the City from out of state) sought declaratory, injunctive, and other relief. They alleged that they were wrongly denied the privileges and immunities guaranteed under the federal constitution because, as to application of the exemption, there was no rational basis or substantial reason for the differential treatment between City residents and nonresidents. The Eliasons and the Hudons noted that, in passing the Ordinance, the City sought to increase funding for the School District. They alleged that lack of adequate school funding, to the extent it exists, is not caused by resident citizens of foreign states moving into the City and purchasing real estate; thus, there is no substantial reason or rational basis for the discrimination between resident citizens of a foreign state and resident citizens of the City. They further alleged that buyers who are residents of foreign states can never qualify or be eligible for the Transfer Tax exemption. For the following reasons, we conclude that the trial court did not err in dismissing count I.\nTo assess whether plaintiffs pleaded a cause of action based upon a violation of the privileges and immunities clause, we briefly review the requirements for showing such a violation. When a law establishes a citizenship or residency classification, a court applies a two-part test in assessing whether the law violates the privileges and immunities clause. First, the court determines whether the benefit or activity constitutes one of the \u201cprivileges and immunities\u201d protected by the clause. United Building & Construction Trades Council, 465 U.S. at 218, 79 L. Ed. 2d at 258, 104 S. Ct. at 1027. Second, the court determines if there is a substantial state interest in the difference in treatment of nonresidents. United Building & Construction Trades Council, 465 U.S. at 222, 79 L. Ed. 2d at 261, 104 S. Ct. at 1029.\nAs to the first part of the test, the Supreme Court has noted that states must treat residents and nonresidents \u201cwithout unnecessary distinctions\u201d when the nonresident seeks to \u201cengage in an essential activity or exercise a basic right.\u201d Baldwin v. Fish & Game Comm\u2019n, 436 U.S. 371, 387, 56 L. Ed. 2d 354, 367, 98 S. Ct. 1852, 1862 (1978). However, if the nonresident engages in conduct that is not \u201cfundamental\u201d because it does not \u201cbea[r] upon the vitality of the Nation as a single entity,\u201d the privileges and immunities clause affords no protection. Baldwin, 436 U.S. at 383, 56 L. Ed. 2d at 365, 98 S. Ct. at 1860. The determination\n\u201cwhether a right is sufficiently fundamental to be protected by the [privileges and immunities] clause should not be confused with a determination of whether an activity constitutes a fundamental right so as to require strict judicial scrutiny under the due process and equal protection clauses when the activity is regulated by the government. For example, the regulation of conditions of employment is not considered a limitation of a fundamental right for due process and equal protection analysis, but the ability to engage in private sector activity or employment is a fundamental right protected by the privileges and immunities clause.\u201d (Emphases added.) 2 R. Rotunda & J. Nowak, Constitutional Law \u00a712.7(d)(ii), at 335-36 (4th ed. 2007).\nAlong with private-sector employment, access to the courts and the disposition of privately held property have been held to be fundamental rights for privileges and immunities clause analysis (see Baldwin, 436 U.S. at 383, 56 L. Ed. 2d at 365, 98 S. Ct. at 1860), as has the right to procure medical services (Doe v. Bolton, 410 U.S. 179, 200, 35 L. Ed. 2d 201, 217, 93 S. Ct. 739, 751 (1973)). However, recreational activities, such as recreational hunting or fishing, are not considered privileges or immunities. Baldwin, 436 U.S. at 388, 56 L. Ed. 2d at 368, 98 S. Ct. at 1863; Toomer v. Witsell, 334 U.S. 385, 403, 92 L. Ed. 1460, 1475, 68 S. Ct. 1156, 1165 (1948). Likewise, suffrage and qualification for elective office may be tied to an individual\u2019s identification with a specific state and are, therefore, not protected by the privileges and immunities clause. See Baldwin, 436 U.S. at 383, 56 L. Ed. 2d at 365, 98 S. Ct. at 1860.\nOn appeal, plaintiffs argue that their complaint sufficiently pleaded that the rights to travel and purchase property are fundamental rights protected by the privileges and immunities clause. Preliminarily, we note that there is some support for the proposition that the rights to travel and purchase property are considered privileges and immunities. See Saenz v. Roe, 526 U.S. 489, 500-01, 143 L. Ed. 2d 689, 702, 119 S. Ct. 1518, 1525 (1999) (discussing the three aspects of the right to travel and noting that the privileges and immunities clause of article IV protects citizens of one state who travel to another state, intending to return home at the end of their journey); Ward v. Maryland, 79 U.S. (12 Wall.) 418, 430, 20 L. Ed. 449, 452 (1871) (the clause \u201cplainly and unmistakably secures and protects the right of a citizen of one State to pass into any other State of the Union for the purpose of engaging in lawful commerce, trade, or business, without molestation; to acquire personal property; to take and hold real estate-, to maintain actions in the courts of the State; and to be exempt from any higher taxes or excises than are imposed by the State upon its own citizens\u201d (emphasis added)); see also Borden v. Selden, 259 Iowa 808, 819, 146 N.W.2d 306, 314 (1966) (statute denying nonresident Iowa landowners a land tax credit that was granted to resident owners held unconstitutional as violating the privileges and immunities clause); Opinion of the Judges, 81 S.D. 629, 632, 140 N.W.2d 34, 35 (1966) (advisory opinion holding that property tax relief act that granted to South Dakota residents a real estate tax refund not allowed to nonresidents was unconstitutional as violating privileges and immunities clause). Assuming that the foregoing rights are fundamental for purposes of the privileges and immunities clause, we conclude that plaintiffs\u2019 complaint has failed to sufficiently plead a violation of the clause.\nIn count I, plaintiffs alleged that, along with laws passed by states, the privileges and immunities clause applies to an ordinance that discriminates on the basis of municipal residency. Nowhere in count I of the complaint did plaintiffs specifically mention the rights to travel and purchase property. Nevertheless, we infer these rights from the allegations referencing \u201cdiscrimination [in application of the Transfer Tax exemption] between resident citizens of a foreign state and resident citizens of\u2019 the City.\nHaving determined that plaintiffs, via their references to the differential treatment of residents and nonresidents, adequately pleaded that the rights to travel and purchase property are privileges and immunities, we conclude that their complaint failed to plead sufficient facts as to the second part of our inquiry. This analysis, i.e., whether there is a substantial state interest in the difference in treatment of nonresidents, consists of two aspects: (1) there must be a substantial reason for the discrimination beyond the fact that they are citizens of other states; that is, there must be something to indicate that noncitizens constitute a \u201cpeculiar source of evil\u201d at which the statute or ordinance is directed; and (2) the court must find a substantial or reasonable relationship between the evil and the discrimination practiced against noncitizens. Hicklin v. Orbeck, 437 U.S. 518, 525-27, 57 L. Ed. 2d 397, 404-05, 98 S. Ct. 2482, 2487-88 (1978); People ex rel. Bernardi v. Leary Construction Co., 102 Ill. 2d 295, 299 (1984).\nPlaintiffs argue that the \u201cevil\u201d at which the Ordinance is directed is inadequate school funding. Indeed, in their amended complaint, plaintiffs alleged that the Ordinance was intended \u201cto create a new source of funds that [the City] will give to the School District to supplement the School District\u2019s operating revenues,\u201d and plaintiffs attached thereto a copy of the Intergovernmental Agreement. The question, plaintiffs assert, is whether nonresidents are the source of the evil. In their complaint, they alleged that there \u201cis no substantial reason, nor rational basis for discriminating between citizens of a foreign state and citizens of [the City], when establishing a transfer tax to increase school funding.\u201d The complaint continued, \u201cLack of adequate school funding, if indeed there is a lack of funding, is not caused by resident citizens of a foreign state moving into [the City] and purchasing real estate, thus, there is no \u2018substantial reason\u2019 nor \u2018rational basis\u2019 for the discrimination between resident citizens of a foreign state and resident citizens of\u2019 the City.\nThe foregoing allegations are clearly conclusory. To survive a section 2 \u2014 615 motion to dismiss, a plaintiff must allege specific facts supporting each element of the cause of action, and we will \u201cnot admit conclusions of law and conclusory allegations not supported by specific facts.\u201d Visvardis, 375 Ill. App. 3d at 724. The foregoing allegations mirror the \u201celements\u201d of the second aspect of our analysis, i.e., substantial reason and substantial relationship, but do not constitute specific factual allegations. Nowhere in count I of their amended complaint did plaintiffs provide any factual allegations supporting their conclusion that residents of a foreign state, such as the Eliasons and the Hudons, who move to the City and purchase real estate do not cause inadequate school funding. In their appellate brief, plaintiffs state that the City \u201cis discriminating against nonresidents who may only be a small part of the cause/source of increased costs in the School District.\u201d (Emphasis added.) They continue, the \u201cfacts could show that the majority of the increased School District costs result from an increase of the school population coming mainly from children born to established residents, from costs of salary increases to existing teachers, or from increased administration or energy costs that are unrelated to an overwhelming mass (if there is one) of new students coming from parents who moved\u201d to the City from outside it. (Emphasis added.) We agree with plaintiffs that the facts could show any of the foregoing sources of the underfunding, but this does not absolve them of their obligation to plead specific facts to state a claim for relief. Because count I of the amended complaint contained, as to the elements of a privileges and immunities clause claim, merely conclusory allegations unsupported by specific facts, we conclude that, as to count I, the trial court did not err in granting defendants\u2019 motion to dismiss.\nB. Count II \u2014 Equal Protection Clause of the Federal Constitution\nIn count II of their amended complaint, plaintiffs alleged that the Ordinance violates the equal protection clause of the fourteenth amendment, which provides that the states may not \u201c \u2018deny to any person within [their] jurisdiction the equal protection of the laws,\u2019 \u201d but does allow reasonable classifications among such persons. Western & Southern Life Insurance Co. v. State Board of Equalization, 451 U.S. 648, 656-57, 68 L. Ed. 2d 514, 523, 101 S. Ct. 2070, 2077 (1981), quoting U.S. Const., amend. XTV\u00a1 \u00a71. They asserted that the Ordinance, by treating plaintiffs disparately from City residents purchasing homestead property, denies them equal protection of the laws.\nIn this count, unlike in count I, plaintiffs specifically alleged that the right to own property is a fundamental right and that the exemption (i.e., the discrimination), based upon a buyer\u2019s residence prior to purchasing real estate in the City, has neither a rational basis nor is it narrowly tailored to the reason the City adopted the Transfer Tax (i.e., to address school underfunding). Plaintiffs noted that the City\u2019s and the School District\u2019s boundaries are not coterminous. The Ordinance, they alleged, violates the equal protection clause by making unconstitutional distinctions among several classifications of buyers: (1) resident and nonresident buyers of real estate; (2) homestead and nonhomestead resident buyers of real estate; (3) persons living within the School District but outside the City who buy homestead property within the City; and (4) persons living in (or moving to) the City who buy homestead or nonhomestead real estate within the City but outside the School District. Plaintiffs asserted that there is no real and substantial difference among the classes of purchasers.\nAs to Rajterowski, plaintiffs alleged that he was wrongly denied equal protection because, prior to purchasing real estate in the City, he already lived in the School District. In plaintiffs\u2019 view, after Rajterowski moved into the City, he did not cause any additional burden to the School District.\nAs to the Skeltons, Eliasons, and Hudons (who lived outside the City and the School District), plaintiffs alleged that there is no rational basis for the disparate treatment of residents and nonresidents. These plaintiffs paid the Transfer Tax that a City resident of more than one year does not have to pay and, therefore, were denied the equal protection of the laws.\nAdditionally, plaintiffs alleged that the exemption is unconstitutional as it applies to resident, nonhomestead purchasers, including corporations, partnerships, or individuals purchasing commercial property. In plaintiffs\u2019 view, a resident corporation or individual purchasing a building for office space places no additional financial burden on the School District and is, therefore, no different from a resident homestead buyer when one considers the City\u2019s only reason for the Ordinance.\nThe first step in assessing an equal protection claim is to determine if the enactment at issue disadvantages a suspect class or infringes upon a fundamental right. Fundamental rights include the expression of ideas, participation in the political process, and intimate personal privacy interests. People ex rel. Tucker v. Kotsos, 68 Ill. 2d 88, 97 (1977). Where the enactment creates a suspect classification or infringes upon a fundamental right, then, under what is called strict-scrutiny review, the enactment must promote a compelling or overriding state interest. Illinois Housing Development Authority v. Van Meter, 82 Ill. 2d 116, 119-20 (1980). Further, the enactment must be narrowly tailored thereto, i.e., the legislature must use the least restrictive means consistent with the attainment of its goal. Schultz v. Lakewood Electric Corp., 362 Ill. App. 3d 716, 720 (2005). Intermediate scrutiny applies to an ordinance that is based on a gender or illegitimacy classification or that causes certain incidental burdens to speech. In re Detention of Samuelson, 189 Ill. 2d 548, 561-62 (2000); Desnick v. Department of Professional Regulation, 171 Ill. 2d 510, 521 (1996). In all other circumstances, courts will review an ordinance under highly deferential rational-basis scrutiny. Samuelson, 189 Ill. 2d at 562. Under the rational-basis test, the enactment must bear a rational relationship to a legitimate governmental interest. Van Meter, 82 Ill. 2d at 120.\nOn appeal, plaintiffs argue that they stated an equal protection claim. They assert that the rights to travel and own property are fundamental rights requiring strict-scrutiny analysis. In their complaint, plaintiffs alleged that the equal protection clause prevents a municipality from discriminating on the basis of residency, without a proper basis for that discrimination. They also specifically alleged that the right to own property is a fundamental right. Alternatively, they argue that, if the foregoing are not fundamental rights, the Ordinance does not survive rational-basis review.\nTurning first to property, we reject plaintiffs\u2019 assertion that the right to private housing, in and of itself, is a fundamental right. See, e.g., Van Meter, 82 Ill. 2d at 121 (the Supreme Court \u201chas clearly ruled that a right to private housing is not a fundamental right\u201d and, thus, applies rational-basis review \u201cto government actions that might burden a person\u2019s ability to find adequate housing\u201d), citing Village of Belle Terre v. Boraas, 416 U.S. 1, 7-9, 39 L. Ed. 2d 797, 803-04, 94 S. Ct. 1536, 1540-41 (1974) (upholding a village zoning ordinance that limited, with certain exceptions, the occupancy of one-family dwellings to traditional families or to groups of not more than two unrelated persons after determining that no fundamental right guaranteed by the federal constitution was involved and, thus, applying rational-basis scrutiny), and Lindsey v. Normet, 405 U.S. 56, 74, 31 L. Ed. 2d 36, 51, 92 S. Ct. 862, 874 (1972) (\u201cWe are unable to perceive in [the federal constitution] any constitutional guarantee of access to dwellings of a particular quality, or any recognition of the right of a tenant to occupy the real property of his landlord beyond the term of his lease without the payment of rent or otherwise contrary to the terms of the relevant agreement\u201d); see also 4 R. Rotunda & J. Nowak, Constitutional Law \u00a718.44, at 411 (4th ed. 2008) (\u201cthe Court has not subjected governmental actions which might burden persons\u2019 abilities to find adequate private housing to any standard of review above the rationality test of the due process and equal protection guarantees. Of course, if these laws involve the use of suspect classifications or burden fundamental rights they will be subjected to the strict scrutiny standard of review\u201d).\nAs to the right to travel, count II of plaintiffs\u2019 complaint did not explicitly mention the right. Rather, they alleged that basing applicability of the exemption on a buyer\u2019s residency prior to purchasing real estate in the City was unconstitutional because it impermissibly distinguished between, inter alla, nonresident (including out-of-state) and resident buyers. We conclude that the assertion that the discrimination against out-of-state residents implicates the right to travel can be reasonably inferred from the complaint\u2019s allegations.\nHaving determined that plaintiffs adequately pleaded that the Ordinance affects the right to travel, we next address the proper level of scrutiny. Plaintiffs urge that, as to the right to travel, strict scrutiny applies, and defendants respond that rational-basis review is appropriate. Case law is not directly on point.\nFor example, laws that establish durational residency requirements for certain governmental benefits are subject to strict-scrutiny review. See, e.g., Shapiro v. Thompson, 394 U.S. 618, 634, 22 L. Ed. 2d 600, 615, 89 S. Ct. 1322, 1331 (1969) (applying strict-scrutiny review and holding invalid as a restriction on the fundamental right to travel a one-year residency requirement for subsistence welfare benefits), overruled on other grounds by Edelman v. Jordan, 415 U.S. 651, 39 L. Ed. 2d 662, 94 S. Ct. 1347 (1974); see also Memorial Hospital v. Maricopa County, 415 U.S. 250, 259, 39 L. Ed. 2d 306, 315, 94 S. Ct. 1076, 1082-83 (1974) (Court, applying strict-scrutiny review, struck down Arizona statute that required one-year residency in a county as a condition of receiving nonemergency hospitalization or medical care at county\u2019s expense; \u201cmedical care is as much \u2018a basic necessity of life\u2019 to an indigent as welfare assistance. And, governmental privileges or benefits necessary to basic sustenance have often been viewed as being of greater constitutional significance than less essential forms of governmental entitlements\u201d); Dunn v. Blumstein, 405 U.S. 330, 338, 31 L. Ed. 2d 274, 281-82, 92 S. Ct. 995, 1001 (1972) (applying strict-scrutiny analysis to invalidate, as violative of rights to travel and vote, Tennessee durational residency law that required a voter to be a resident of the state for one year and of the county for three months before the voter could vote).\nIn Attorney General v. Soto-Lopez, 476 U.S. 898, 911, 90 L. Ed. 2d 899, 911,106 S. Ct. 2317, 2325 (1986), the Court, in a plurality opinion, invalidated a New York statute and constitutional provision that provided a preference in civil service employment to veterans who lived in the state when they entered military service, but denied a similar preference to resident veterans who lived outside the state when they entered military service. Justice Brennan delivered the opinion of the Court and noted that strict-scrutiny review should apply. Soto-Lopez, 476 U.S. at 906, 90 L. Ed. 2d at 907, 106 S. Ct. at 2322.\nIn other factual scenarios, the Supreme Court has declined to define the appropriate standard, although it has nevertheless struck down the enactments as unconstitutional under rational-basis review. In Hooper v. Bernalillo County Assessor, 472 U.S. 612, 86 L. Ed. 2d 487, 105 S. Ct. 2862 (1985), for example, the Supreme Court considered whether a New Mexico statute that granted a $2,000 property tax exemption to Vietnam veterans who resided in the state before May 8, 1976, but not to those who resided in the state on or after that date, violated the equal protection clause of the fourteenth amendment. The Court did not address the proper standard of review to be applied in right-to-travel cases, noting that if the statutory scheme does not pass even the rationality test, the Court\u2019s inquiry ends. Hooper, 472 U.S. at 618, 86 L. Ed. 2d at 493, 105 S. Ct. at 2866. The Court held that the discrimination the statute made between veterans who established residency before the statutory date and those who arrived thereafter bore no rational relationship to one of the state\u2019s objectives \u2014 encouraging veterans to move to New Mexico\u2014 because the state set the eligibility date long after the triggering event, the date, had occurred. Hooper, 472 U.S. at 619, 86 L. Ed. 2d at 494, 105 S. Ct. at 2866-67. Next, the Court addressed the statute\u2019s second purpose \u2014 to reward veterans who served before May 8, 1976. The Court noted that resident veterans may be offered preferential treatment vis-\u00e1-vis nonveterans without offending the equal protection clause, but the statute at issue was problematic because it conferred a benefit only on established resident veterans \u2014 those who resided in the state before the statutory date. Hooper, 472 U.S. at 620-21, 86 L. Ed. 2d at 494-95, 105 S. Ct. at 2867-68. \u201cThe State may not favor established residents over new residents based on the view that the State may take care of \u2018its own,\u2019 if such is defined by prior residence. Newcomers, by establishing bona fide residence in the State, become the State\u2019s \u2018own\u2019 and may not be discriminated against solely on the basis of their arrival in the State after May 8, 1976.\u201d Hooper, 472 U.S. at 623, 86 L. Ed. 2d at 496, 105 S. Ct. at 2868. Accordingly, the Court held that the equal protection clause did not permit the State to establish a preference for established resident veterans over newcomers in the retroactive apportionment of an economic benefit. Hooper, 472 U.S. at 623, 86 L. Ed. 2d at 497, 105 S. Ct. at 2869; see also Zobel v. Williams, 457 U.S. 55, 60-64, 72 L. Ed. 2d 672, 677-80, 102 S. Ct. 2309, 2313-15 (1982) (refusing to adopt a standard of review and invalidating, as not withstanding even rational-basis scrutiny, Alaska\u2019s statutory scheme to distribute to its adult citizens income derived from its petroleum revenues in varying amounts based upon their length of residency in the state; right to travel implicated because statute distinguished between residents based upon when they arrived in the state).\nIn another right-to-travel case, the Court did not discuss the level of scrutiny, although, arguably, in upholding a law, it applied rational-basis review. See Sosna v. Iowa, 419 U.S. 393, 406-09, 42 L. Ed. 2d 532, 544-46, 95 S. Ct. 553, 561-62 (1975) (upholding one-year residency requirement for maintaining divorce action on the basis that the state had a strong, traditional interest in setting the terms of and procedures for marriage and divorce; right to migrate not violated as appellant\u2019s access to desired state procedure was only temporarily delayed and because state may reasonably desire to insulate divorce decrees from collateral attack).\nWe conclude that rational-basis review is appropriate in this case. The Soto-Lopez Court held that the right to civil service employment, although not a necessity of life or the right to vote, \u201cis unquestionably substantial. The award of bonus points can mean the difference between winning or losing civil service employment, with its attendant job security, decent pay, and good benefits.\u201d Soto-Lopez, 476 U.S. at 908, 90 L. Ed. 2d at 909, 106 S. Ct. at 2324. Also, the Court noted that the appellees had been permanently deprived of the veterans\u2019 credits they sought. Soto-Lopez, 476 U.S. at 909, 90 L. Ed. 2d at 909, 106 S. Ct. at 2324. \u201cSuch a permanent deprivation of a significant benefit, based only on the fact of nonresidence at a past point in time, clearly operates to penalize appellees for exercising their rights to migrate.\u201d Soto-Lopez, 476 U.S. at 909, 90 L. Ed. 2d at 909, 106 S. Ct. at 2324.\nWe conclude that private housing (or a property tax exemption) does not constitute a significant benefit or privilege like civil service employment (Soto-Lopez), subsistence welfare benefits {Shapiro), non-emergency hospitalization or medical care {Memorial Hospital), or voting rights {Dunn). See also, e.g., Sylvester v. Commissioner of Revenue, 445 Mass. 304, 311, 837 N.E.2d 662, 667-68 (2005) (rational-basis review appropriate in assessing whether five-year residency requirement for partial real estate tax exemption for disabled veterans violated right to travel protected by equal protection clause; \u201cresidency requirement in the veterans\u2019 exemption does not prevent new arrivals from purchasing property in Massachusetts or from establishing a domicile here. It recognizes that the plaintiff, as a taxpayer, has no right to a particular rate of taxation, and it is underpinned *** by the well-settled law\u201d protecting states from undue federal interference in the tax field); cf. Ball v. Village of Streamwood, 281 Ill. App. 3d 679, 683-85 (1996) (applying rational-basis review to determine whether a real estate transfer tax imposed on sellers but exempting those who purchased residences within the village violated the right to intrastate travel protected by the equal protection clause; court concluded that no vital government benefit or privilege was involved).\nThus, we now assess whether plaintiffs stated a claim that the Ordinance, under rational-basis review, infringes on the rights to housing and travel in violation of equal protection. Plaintiffs argue that they stated a claim that the Ordinance bears no rational relationship to a legitimate governmental interest because there is no rational basis for creating a class of persons, such as Rajterowski, who live in the School District and pay taxes to fund the schools but live outside the corporate limits of the City, and treating them differently from people who live in both the School District and the City. Also, they contend that there is no rational basis for charging new residents a transfer tax when these same persons will be paying property taxes, just like other City residents, to support the School District. Finally, they urge that it was not appropriate to dismiss this case under section 2 \u2014 615, because there is case law invalidating state laws under rational-basis review. See Hooper, 472 U.S. at 623, 86 L. Ed. 2d at 497, 105 S. Ct. at 2869; Zobel, 457 U.S. at 60-64, 72 L. Ed. 2d at 677-80, 102 S. Ct. at 2313-15.\nDefendants respond that the Ordinance, on its face, demonstrates, as does the Intergovernmental Agreement, that its purpose is to increase school funding to help offset the costs associated with new students moving into the City. Exempted from the tax are established residents who will not add new burdens to the schools when they purchase new homes in the City. Residents under this classification, according to defendants, do not create an additional burden to the district; conversely, nonresident homestead purchasers do add to the economic burden by potentially increasing the number of children entitled to attend the public schools. Requiring this class to pay the Transfer Tax rationally and legitimately advances the City\u2019s purpose for passing the Ordinance. Defendants urge that plaintiffs\u2019 allegations support the rational purpose and legitimate goal for the Transfer Tax \u2014 supplemental school funding. Defendants also assert that it is beyond dispute that providing adequate public schools is a legitimate governmental goal. Finally, they argue that the Ordinance does not violate equal protection merely because the City and the School District boundaries are not coterminous. Defendants contend that the fit need not be perfect; it need only avoid being arbitrary. For example, the fact that Rajterowski was not exempt from the Transfer Tax does not invalidate the Ordinance because it does not negate the Ordinance\u2019s legitimate purpose or make it discriminatory.\nWe conclude that plaintiffs failed to state a claim that the Ordinance is not rationally related to a legitimate governmental interest. \u201cThe rational basis test is particularly deferential in the context of classification made by tax laws, and if a set of facts can be reasonably conceived that would sustain the classification, the tax must be upheld.\u201d Ball, 281 Ill. App. 3d at 683. Plaintiffs\u2019 allegations that the Transfer Tax\u2019s purpose \u2014 to address school underfunding \u2014 targets only certain classes of residents do not show that the law is arbitrary. The allegations, rather, reflect that the Ordinance makes a reasonable distinction between those adding new burdens to the schools (who are subject to the Transfer Tax) and those who do not add to the underfunding (who are exempt from paying the tax). That the \u201cfit\u201d is not perfect, due to the lack of coterminous boundaries, does not cause the law to fail for being arbitrary, under rational-basis review. City of New Orleans v. Dukes, 427 U.S. 297, 303, 49 L. Ed. 2d 511, 517, 96 S. Ct. 2513, 2517 (1976) (\u201cStates are accorded wide latitude in the regulation of their local economies under their police powers, and rational distinctions may be made with substantially less than mathematical exactitude. Legislatures may implement their program step by step\u201d).\nHooper and Zobel, wherein the Court struck down the enactments at issue as not withstanding even rational-basis review, do not compel a different conclusion. Although Hooper involved a property tax exemption, the residency requirement in that case was a fixed-date requirement: the New Mexico statute provided a property tax exemption for Vietnam veterans who had established residency in the state before May 8, 1976. Hooper, 472 U.S. at 618, 86 L. Ed. 2d at 493, 105 S. Ct. at 2862. The Court noted, quoting Zobel, that \u201cthe Constitution will not tolerate a state benefit program that \u2018creates fixed, permanent distinctions ... between ... classes of concededly bona fide residents, based on how long they have been in the State.\u2019 \u201d Hooper, 472 U.S. at 623, 86 L. Ed. 2d at 496, 105 S. Ct. at 2869, quoting Zobel, 457 U.S. at 59, 72 L. Ed. 2d at 677, 102 S. Ct. at 2312. Here, the exemption is not a fixed-date enactment.\nIn sum, we conclude that the trial court did not err in dismissing count II of plaintiffs\u2019 amended complaint.\nC. Count III \u2014 Uniformity Clause of the Illinois Constitution\nThe uniformity clause of the Illinois Constitution provides that, \u201c[i]n any law classifying the subjects or objects of non-property taxes or fees, the classes shall be reasonable and the subjects and objects within each class shall be taxed uniformly. Exemptions, deductions, credits, refunds and other allowances shall be reasonable.\u201d Ill. Const. 1970, art. IX, \u00a72.\nIn count III of their amended complaint, plaintiffs alleged that the Ordinance\u2019s exemption violates the uniformity clause. They noted that the object of the Ordinance is to tax purchasers who move into the City who bring new students into the School District from outside the City, because they are the cause of the inadequate school funding. Plaintiffs alleged that the Ordinance created several classes of taxpayers: resident buyers who purchase nonhomestead property; resident buyers purchasing homestead property; and nonresident buyers purchasing homestead property. As to the first class, plaintiffs alleged that there is no real and substantial difference between resident homestead purchasers and resident nonhomestead purchasers and that the classification does not bear some reasonable relationship to the object of the Ordinance, especially when \u201cthe only reason\u201d the City adopted the Ordinance was to address the School District\u2019s additional financial burden that stems from new students moving into the district. In plaintiffs\u2019 view, the resident nonhomestead purchasers are not adding to the School District\u2019s burden, yet they are not entitled to the same exemption as resident homestead purchasers.\nAs to the second and third classifications, plaintiffs alleged that distinguishing between resident and nonresident homestead buyers does not bear some reasonable relationship to the object of the Ordinance when the reason for the Ordinance is to address the School District\u2019s additional financial burden that stems from new students moving into the district. They alleged that there is no exemption for nonresident buyers who do not have children or whose children do not attend public school in the School District (such as Rajterowksi); the Ordinance does not exempt buyers who move to the City but already lived in the School District (but outside the City) and thus were already paying property taxes and fees and are not bringing new students into the School District; and the Ordinance does not tax buyers who move into the School District but outside the City and who are bringing new children into the School District. Finally, they alleged that the Ordinance does not exempt nonresident or resident nonhomestead buyers moving into areas of the City that are not within the School District.\nPlaintiffs further asserted that, if the School District is underfunded, the causes could be declining property tax revenue, increases in the number of children of City residents who qualify for the exemptions, increases in salary, changes in the amount of state and federal aid, increases in insurance costs, and other expenses. The complaint cited to a study, the \u201c2007 Sycamore Housing Impact Analysis\u201d prepared by Strategic Management Alliance in June 2007 (Study), which is not contained in the record on appeal. Plaintiffs alleged that the Study did not quantify the number of new students coming into the School District who were previously non-City residents. They alleged that the City \u201chas not and can not actually demonstrate and determine the number of children moving into Sycamore from outside of Sycamore.\u201d Plaintiffs noted that the Study stated that 22.3% of new home buyers were from the City; that 49% of new detached homes built since June 2004 had no children living in them at the point of initial occupancy; and that 91% of townhouses and condominiums built during that time had no children living in them at initial occupancy. Further, plaintiffs quoted from the Study with respect to sales of existing homes to non-City buyers: \u201c \u2018The average of 2.60 people per existing housing unit re-occupied in 2006 is slightly lower than the Special Census findings from 2005 which showed 2.68 people lived in Sycamore\u2019s owner-occupied homes on average. This difference does not prove that there are less children, but it does suggest there are less people overall.\u2019 \u201d Plaintiffs also quoted the following from the Study: \u201c \u2018The findings suggest that, of those who responded to the mail survey who were transfer taxpayers [i.e., nonresident purchasers], 18% said that they were not sending their children to Sycamore schools.\u2019 \u201d Plaintiffs alleged that the foregoing statements do not support the assertion that a large number of new students are coming into the City from outside and causing an economic burden on the School District. Thus, the difference among the classifications, in their view, is not real and substantial and the exemptions as drawn are unreasonable because there is no reasonable relationship between those taxed and those exempted. Finally, they assert that there is no reasonable relationship to the object of the legislation when the tax applies to purchasers who end up residing in those portions of the City that do not lie within the School District. For the following reasons, we conclude that the trial court did not err in dismissing count III.\n\u201cTo survive scrutiny under the uniformity clause, a nonproperty tax or fee classification must: (1) be based on a real and substantial difference between the people taxed and those not taxed; and (2) bear some reasonable relationship to the object of the legislation or to public policy.\u201d (Emphases added.) Valstad v. Cipriano, 357 Ill. App. 3d 905, 914 (2005). \u201cA plaintiff is not required to come forward with any and all conceivable explanations for the tax and then prove each one unreasonable ***.\u201d Geja\u2019s Caf\u00e9 v. Metropolitan Pier & Exposition Authority, 153 Ill. 2d 239, 248 (1992). Rather, upon a good-faith uniformity challenge, the taxing body bears the \u201cburden of producing a justification for the classification.\u201d Valstad, 357 Ill. App. 3d at 914; see also Geja\u2019s Caf\u00e9, 153 Ill. 2d at 248. Next, \u201cplaintiff bears the burden of persuading the court that the justification is not supported by facts or is insufficient as a matter of law.\u201d Valstad, 357 Ill. App. 3d at 914. Where the plaintiff fails to meet his or her burden, judgment is proper as a matter of law. Geja\u2019s Caf\u00e9, 153 Ill. 2d at 249; see also Valstad, 357 Ill. App. 3d at 914.\nThis court\u2019s inquiry under a uniformity clause challenge is relatively narrow:\n\u201c[T]he court is not required to have proof of perfect rationality as to each and every taxpayer. The uniformity clause was not designed as a straitjacket for the General Assembly. Rather, the uniformity clause was designed to enforce minimum standards of reasonableness and fairness as between groups of taxpayers.\u201d Geja\u2019s Caf\u00e9, 153 Ill. 2d at 252.\nThe uniformity clause \u201cwas not made to duplicate the limitation on the taxing power contained in the equal protection clause.\u201d Searle Pharmaceuticals, Inc. v. Department of Revenue, 117 Ill. 2d 454, 467 (1987). Rather, the clause \u201cimposes more stringent limitations than the equal protection clause on the authority of a legislative body to classify the subjects and objects of taxation.\u201d DeWoskin, 306 Ill. App. 3d at 518. Nevertheless, a court\u2019s analysis is of limited scope because legislative enactments carry the presumption of validity and because broad latitude is granted to legislative classifications for taxing purposes. Allegro Services, Ltd. v. Metropolitan Pier & Exposition Authority, 172 Ill. 2d 243, 250 (1996).\nAs to the first part of our inquiry, i.e., whether the exemption is based upon a real and substantial difference between the people taxed and the people not taxed, this element is essentially conceded in defendants\u2019 favor on appeal. In their amended complaint, plaintiffs alleged, in a conclusory fashion, that there is no real and substantial difference between resident homestead purchasers and resident nonhomestead purchasers. They also alleged, again in a conclusory fashion, that there is no real and substantial difference between resident and nonresident homestead purchasers. On appeal, plaintiffs concede that there is a factual distinction between resident and nonresident buyers of homestead real estate.\nAs to the second part of our inquiry, whether the tax classification bears some reasonable relationship to the object of the enactment or to public policy, plaintiffs argue that the need for funding for the School District is not reasonably related to the classification of resident buyers of homestead real estate versus nonresident buyers of homestead real estate. They note that nonresidents moving into the City who have no children do not add any economic strain to the School District. According to plaintiffs, City residents who are also School District residents do cause financial strain on the School District. Nonresidents moving into the City and the School District \u201cmay\u201d cause financial strain, \u201cbut not any more of a strain than the residents who are already burdening the School District.\u201d Plaintiffs assert that the stated purpose of the Ordinance, to fund the School District, cannot be met when it taxes those who may perhaps cause financial strain on the School District in the future, while failing to tax the one group known to already cause financial strain on the School District. Further, plaintiffs argue that the City cannot determine the number of children moving into the City from outside the City. As they did in their complaint, plaintiffs note that the City\u2019s Study did not quantify the new students entering the School District from outside the City. Plaintiffs argue that the Study shows that nonresidents are not causing a school funding crisis. Thus, the differential classification between residents and nonresidents is not reasonably related to the school funding issue. Plaintiffs contend that, once a nonresident becomes a resident, he or she begins paying property taxes to fund his or her use of the schools. An additional tax based upon the nonresident\u2019s failure to pay past property taxes for a benefit he or she was not receiving prior to purchasing property within the City is not reasonable. Plaintiffs argue that this is especially true given that the only group certain to use those benefits is the one group exempt from paying the tax.\nAdditionally, plaintiffs take issue with the fact that the Ordinance does not exempt purchasers of nonhomestead real property, including residents who purchase nonhomestead real property. They note that the exemption does not apply to any buyers of commercial property, even though these buyers do not put any more strain on the School District than resident buyers of homestead real estate, the only group excluded from paying the Transfer Tax. Finally, plaintiffs argue that a uniformity clause analysis necessarily requires analysis of the facts and circumstances surrounding the Ordinance\u2019s enactment and purpose and a determination of the least restrictive means of achieving the legislative goal and, thus, precludes dismissal on the pleadings.\nDefendants respond that the face of plaintiffs\u2019 amended complaint provides a reason for the Ordinance that is clearly related to the classification of resident purchasers of homestead property as exempt from paying the Transfer Tax. They point to plaintiffs\u2019 allegation that \u201c[t]he object of the legislation is to tax buyers who move into Sycamore who bring new students into the School District from outside of Sycamore because the Defendant\u2019s [sic] assert that is what is causing what Defendant[s] believe to be inadequate school funding.\u201d Defendants further note that plaintiffs alleged that the \u201conly reason\u201d the City adopted the Ordinance \u201cis to address the additional financial burden to the School District that stems from new students moving into the School District.\u201d Defendants argue that a reasonable basis for the classification exempting resident homestead purchasers, who \u201cby definition\u201d will not be bringing new students into the School District, was actually pleaded in the amended complaint.\nAs to nonhomestead property, defendants argue that such purchasers include those who will use the property as rental property, which could reasonably be expected to add families that would add to the School District\u2019s financial burden. Nonhomestead property also includes commercial property, which, defendants assert, adds to a community\u2019s growth, which necessarily increases the burden upon the School District. Thus, defendants reason, when nonhomestead property is purchased, the Transfer Tax imposed upon the purchase at the very least bears some reasonable relation to the purchase. Next, as to the Study, defendants argue that: (1) plaintiffs\u2019 allegation that the City cannot demonstrate the number of children moving into the City from outside it has no factual basis in the complaint; (2) quantification of the children entering the City is not essential to the inquiry because it is clear that homestead purchasers who already live in the City will not be burdening the School District with additional students by virtue of their purchase of new homesteads within the City, while nonresident homestead purchasers \u201chave the clear potential to do so\u201d; and (3) the burden is not on defendants to prove any particular set of facts; so long as there is a set of facts that can reasonably be conceived that would sustain the classification, as there is here, the classification must be upheld.\nWe address first plaintiffs\u2019 argument that a uniformity clause challenge necessarily involves a factual analysis and, therefore, precludes dismissal on the pleadings. We disagree. It has been noted that, in the context of a uniformity clause challenge, a section 2 \u2014 615 motion \u201cis generally *** inappropriate\u201d because such claims involve a burden-shifting arrangement and summary judgment \u201cis more suited to the task.\u201d DeWoskin, 306 Ill. App. 3d at 523. However, \u201c[w]hen the reasonableness of a tax classification is determinable as a matter of law, a uniformity challenge may be decided in the context of a section 2 \u2014 615 motion.\u201d DeWoskin, 306 Ill. App. 3d at 523 (movie theater patron challenged county amusement tax; court held that as a matter of law, there was a reasonable basis for exempting from county amusement tax patrons of organizations benefitting community and not patrons of commercial organizations; exclusion of raffles and inter-track wagering facilities from the definition of amusement was reasonable because participatory activities and the operation of amusement devices are fundamentally different from passive entertainment, and their exclusion was not arbitrary or unreasonable as a matter of law; however, whether the size of an entertainment facility or the frequency with which an entity offered amusement activities justified an exemption presented factual questions, as did the assessment of an exemption for amusements sponsored by military and veterans organizations).\nAs to the Ordinance\u2019s differential treatment of residents and nonresidents, we conclude as a matter of law that the exemption from the Transfer Tax for residents (but not for nonresidents) bears a reasonable relationship to the school underfunding issue. It is certainly reasonable to impose upon new residents the one-time burden, via the Transfer Tax, of contributing to the maintenance of a School District. New residents are a reasonable class to target for the imposition of such a burden, as they generally will add to the school population and costs. Plaintiffs\u2019 attempt to characterize the Ordinance as imposing a tax burden on new residents for past school underfunding issues (for which they necessarily are not responsible) is unavailing because it is not clear on this record that this is the Ordinance\u2019s purpose. We cannot discern from this record that the Ordinance\u2019s purpose (sole or otherwise) is to address an existing underfunding issue. It is equally plausible/reasonable to read the Ordinance as a forward-looking enactment that seeks to have new users of the schools (i.e., primarily new City residents) bear the cost at the commencement of their City residency for the impact they, as a group, will have on the School District\u2019s finances. We will not second-guess the City\u2019s determination that property taxes alone are inadequate to address the added financial burden that new students/residents impose on the schools.\nPlaintiffs\u2019 reliance on the Study is misplaced, as the excerpts recited in the amended complaint do not provide a sufficient factual basis for plaintiffs\u2019 allegation that new residents are not causing school underfunding. Indeed, the excerpts themselves undercut plaintiffs\u2019 allegations: (1) the \u201cdifference [i.e., the slight decrease from 2005 to 2006 in the average number of people in existing homes purchased by non-City buyers] does not prove that there are less children, but it does suggest that there are less people overall\u201d (emphasis added); (2) \u201c22.3% of new home buyers were from Sycamore,\u201d which implies that the overwhelming majority (almost 80%) were nonresidents; (3) \u201c49% of new detached homes built since June of 2004 had no children at all living in them at the point of initial occupancy,\u201d which implies that 51%, or a majority, did have children living in them; and (4) \u201cof those who responded to the mail survey who were transfer taxpayers [i.e., nonresident purchasers], 18% said that they were not sending their children to Sycamore schools,\u201d which implies that the overwhelming majority were doing so.\nAs to the Ordinance\u2019s treatment of homestead and nonhomestead purchasers, we conclude as a matter of law that the exemption from the Transfer Tax for homestead purchasers (but not for nonhomestead purchasers) bears a reasonable relationship to the issue of school funding. The uniformity clause does not require that the class taxed be the sole or primary beneficiary of the tax. Arangold Corp. v. Zehnder, 329 Ill. App. 3d 781, 798 (2002). \u201cRather, courts have held that uniformity is satisfied even when those taxed benefit only indirectly [citation], or when others not taxed benefit as well.\u201d Arangold, 329 Ill. App. 3d at 798. As defendants note, commercial property encompasses rental property, and renters could reasonably be expected to add to the School District\u2019s student population. Further, nonresidential commercial property can reasonably be expected to add to a community\u2019s growth through additional employment opportunities. These opportunities certainly attract to the City families whose children would generally be expected to attend the public schools.\nFor similar reasons, plaintiffs\u2019 allegations that certain other classifications should have been exempted from the tax fail. They complain that there is no exemption for nonresident purchasers who have no children or whose children do not attend public schools. Plaintiffs also protest that there is no exemption for purchasers who formerly lived in the School District and moved to the City and for purchasers who move to areas of the City that are not within the School District. Plaintiffs\u2019 allegations fail to sufficiently state a uniformity clause claim because, as we noted above with respect to nonhomestead purchasers, there exists an interrelationship wherein those classifications of taxpayers indirectly benefit as a result of the Transfer Tax.\nBall v. Village of Streamwood, 281 Ill. App. 3d 679 (1996), is instructive. In Ball, taxpayers challenged the constitutionality of an exemption to a village\u2019s real estate transfer tax that was imposed, unlike in this case, upon sellers of real property. The exemption relieved sellers who purchased new residences within the village from payment of the transfer tax. In assessing a certified question asking whether the exemption violated the taxpayers\u2019 rights to uniformity, the court first concluded that there was a difference between those taxed (those relocating outside the village) and those not taxed (those remaining in the village). Ball, 281 Ill. App. 3d at 685. Next, the court addressed whether the classification bore a reasonable relationship to the object of the enactment. Referring to its earlier holding (in assessing, under rational-basis review, whether the exemption violated the taxpayers\u2019 rights to intrastate travel) that the village articulated \u201ca rational basis for structuring its tax in this manner\u201d {Ball, 281 Ill. App. 3d at 685), specifically, that the exemption encouraged community continuity and values, the court concluded that the tax and the exemption did not violate the uniformity clause of the Illinois Constitution. Ball, 281 Ill. App. 3d at 685; see also Stahl v. Village of Hoffman Estates, 296 Ill. App. 3d 550, 558-59 (1998) (finding Ball controlling and affirming section 2 \u2014 615 dismissal of action challenging constitutionality of transfer tax exemption for sellers who lived on the property for one year if they purchased another residence in the village within a certain period; the taxpayers who challenged the exemption moved out of the village after transferring their property).\nArguably, school underfunding presents a more pressing issue than the preservation of community continuity or values, as was the issue in Ball. In any event, the community-values-and-continuity rationale present in Ball is also a consideration here due to, as we noted above, the interrelationship between various community groups and the quality/funding of the community\u2019s public schools.\nIn sum, we conclude that the trial court did not err in dismissing count III of plaintiffs\u2019 amended complaint.\nD. Count IV \u2014 the City\u2019s Constitutional Authority\nIn count IV plaintiffs alleged that, in enacting the Ordinance and entering into the Intergovernmental Agreement, the City, a home rule unit, exceeded its constitutional {i.e., home rule) authority in two respects: it (1) circumvented the School Code (105 ILCS 5/1 \u2014 1 et seq. (West 2008)); and (2) exceeded its jurisdiction. For the following reasons, we conclude that the trial court did not err in dismissing count IV\nPreliminarily, we note that the Illinois Constitution provides that \u201c[h]ome rule units may exercise and perform concurrently with the State any power or function of a home rule unit to the extent that the General Assembly by law does not specifically limit the concurrent exercise or specifically declare the State\u2019s exercise to be exclusive.\u201d (Emphases added.) Ill. Const. 1970, art. VII, \u00a76(i). Home rule units\u2019 powers are liberally construed. Ill. Const. 1970, art. VII, \u00a76(m). As previously noted, a transfer tax in and of itself does not \u201coffend any constitutional provisions.\u201d Stahl, 296 Ill. App. 3d at 554; see also 65 ILCS 5/8 \u2014 3\u201419 (West 2006) (authorizing home rule municipalities to impose, upon prior approval by referendum, real estate transfer taxes).\nThe constitution permits intergovernmental cooperation. It provides:\n\u201cUnits of local government and school districts may contract or otherwise associate among themselves *** to obtain or share services and to exercise, combine, or transfer any power or function, in any manner not prohibited by law or by ordinance. *** Participating units of government may use their credit, revenues, and other resources to pay costs and to service debt related to intergovernmental activities.\u201d (Emphasis added.) Ill. Const. 1970, art. VII, \u00a710(a).\nSimilarly, the Intergovernmental Cooperation Act addresses intergovernmental cooperation: and expressly prohibited by law.\u201d (Emphasis added.) 5 ILCS 220/3 (West 2008).\n\u201cAny power or powers, privileges, functions, or authority exercised or which may be exercised by a public agency of this State may be exercised, combined, transferred, and enjoyed jointly with any other public agency of this State and jointly with any public agency of any other state or of the United States to the extent that laws of such other state or of the United States do not prohibit joint exercise or enjoyment and except where specifically\nThe Intergovernmental Cooperation Act also permits intergovernmental contracts:\n\u201cAny one or more public agencies may contract with any one or more other public agencies to perform any governmental service, activity or undertaking or to combine, transfer, or exercise any powers, functions, privileges, or authority which any of the public agencies entering into the contract is authorized by law to perform, provided that such contract shall be approved by the governing bodies of each party to the contract and except where specifically and expressly prohibited by law. Such contract shall set forth fully the purposes, powers, rights, objectives and responsibilities of the contracting parties.\u201d (Emphasis added.) 5 ILCS 220/5 (West 2008).\nAs to the first aspect of count IV, plaintiffs alleged that the Ordinance created a new source of funds to supplement the School District\u2019s operating revenues and, as such, circumvented the School Code\u2019s (105 ILCS 5/1 \u2014 1 et seq. (West 2008)) procedures for raising tax revenues for schools. Plaintiffs alleged that, in the School Code, the legislature established a mechanism for funding public education. Plaintiffs alleged that increases in school funding must be the subject of proper school board resolution and that the school board must submit to the School District\u2019s voters for referendum a proposition to increase the annual tax rate for educational purposes. 105 ILCS 5/17 \u2014 3 (West 2008). They further alleged that the Ordinance that adopted the Transfer Tax (that is to be used to fund the School District) was not a referendum submitted to all School District voters and was not treated as a tax levy for educational purposes, as required by the School Code. Conceding that some statutes specifically authorize municipalities to give certain portions of their tax revenues to public school districts, plaintiffs alleged that there is no statutory authority, including the School Code, permitting a municipality to give Transfer Tax revenues to any public school district. Accordingly, they alleged that the City, without legal authority, circumvented the School Code by raising tax revenues for schools without following the procedures set forth in the statute.\n\u201c[T]he legislature has enacted a comprehensive scheme for the creation, management and operation of Illinois schools. *** Thus the legislature, pursuant to the constitutional mandate, exercises plenary power over the Illinois school system.\u201d Board of Education of School District No. 150 v. City of Peoria, 76 Ill. 2d 469, 476 (1979); see also Ill. Const. 1970, art. X, \u00a71 (\u201cThe State has the primary responsibility for financing the system of public education\u201d (emphasis added)).\nSection 17 \u2014 3 of the School Code, upon which plaintiffs rely, addresses additional tax levies and provides, in relevant part:\n\u201cThe school board in any district having a population of less than 500,000 inhabitants may, by proper resolution, cause a proposition to increase, for a limited period of not less than 3 nor more than 10 years or for an unlimited period, the annual tax rate for educational purposes to be submitted to the voters of such district at a regular scheduled election.\u201d (Emphases added.) 105 ILCS 5/17 \u2014 3 (West 2008).\nDefendants respond that the City may share with the School District the revenue generated by the Transfer Tax. They note that, as a home rule entity, the City can exercise any power pertaining to its government and affairs (Ill. Const. 1970, art. VII, \u00a76(a)). Further, defendants assert that both the constitution and statutes permit intergovernmental cooperation. As to the School Code, defendants argue that it does not prohibit a school district from receiving funds from sources other than its own property tax levy and, in any event, the City, not the School District, passed the Ordinance at issue. The City, according to defendants, is not subject to the School Code\u2019s provisions. The statute establishes a mechanism by which a school district may submit a referendum to its voters to increase the district\u2019s annual tax levy; in enacting the Ordinance, the City did not and could not increase the School District\u2019s annual tax levy or circumvent the School Code. Defendants argue that School District funding pertains to the City\u2019s government and affairs because it promotes the general prosperity and welfare of the community and that the expenditure of tax money need not benefit all taxpayers equally to be constitutional.\nWe agree with defendants that plaintiffs\u2019 reliance on section 17 \u2014 3 of the School Code is misplaced because that provision addresses the obligations of school boards, not municipalities. We also agree with defendants that, in their complaint, plaintiffs pointed to no provision in the School Code that specifically restricts a municipality\u2019s powers to forward monies to school districts. Further, the constitution provides that the State has primary responsibility for financing public education. Ill. Const. 1970, art. X, \u00a71. However, it does not confer on the State exclusive responsibility for school funding. Because a home rule unit may exercise concurrently with the State any power of a home rule unit, in the absence of any specific legislative limitation on home rule units\u2019 powers, or the State\u2019s exclusive exercise of power, over schools, we cannot conclude that plaintiffs stated a claim that the City exceeded its authority by circumventing the School Code.\nWe find City of Peoria instructive. In that case, a home rule municipality enacted ordinances imposing taxes upon the witnessing of or participation in amusements and upon the privilege of purchasing food or alcoholic beverages served at restaurants or taverns. The taxes were paid by consumers, but the ordinances also imposed on establishment operators and owners the duties of collecting the taxes and keeping records of tax receipts and imposed on them the obligation to file tax returns reflecting such receipts. The school district and park district challenged the ordinances as unenforceable against them. As to the school district, the supreme court held that the ordinances imposed duties upon the board of education that were not authorized, such as the keeping of records, examination of books, and collection of the taxes. City of Peoria, 76 Ill. 2d at 476-77. These duties were over and above those imposed upon the entity by the legislature. City of Peoria, 76 Ill. 2d at 476-77. Further, the court held that the ordinances conferred on the school district powers that it did not have by statute, such as the power to collect taxes on behalf of the city and to hold them as trustee. City of Peoria, 76 Ill. 2d at 477. Thus, the ordinances constituted the unauthorized regulation of the school district, contrary to the constitution (Ill. Const. 1970, art. X, \u00a71 (\u201cThe State shall provide for an efficient system of high quality public educational institutions and services\u201d)). City of Peoria, 76 Ill. 2d at 477.\nCity of Peoria is distinguishable because, in that case, the municipality\u2019s ordinances burdened the school district by requiring it to, among other things, collect the municipal tax and maintain records. Here, the Transfer Tax merely confers benefits to the School District by forwarding to it funds to enable the district to carry out its operations. This distinction is critical because the City, via the Ordinance and by entering into the Intergovernmental Agreement, has neither infringed on the State\u2019s power nor burdened the School District.\nPlaintiffs next argue that the City has no obligation to solve a school revenue shortage and, thus, any transfer of funds to the district constitutes a donation or gift. In plaintiffs\u2019 view, the City cannot donate money to the School District because this does not pertain to the City\u2019s government and affairs. See Ill. Const. 1970, art. VII, \u00a76(a) (\u201ca home rule unit may exercise any power and perform any function pertaining to its government and affairs including, but not limited to, the power *** to tax\u201d).\nPlaintiffs rely on an Attorney General opinion that addressed a proposed agreement to share sales tax revenue between the City of Belleville, a home rule unit, and St. Clair County. 1978 Ill. Att\u2019y Gen. Op. 165. The proposed agreement provided that, whenever the city received sales tax revenue from businesses located in territory that had been newly annexed by the city, the city would share a portion of the tax with the county, which was no longer receiving tax revenues from the businesses. The county was not obligated to provide the city with any consideration for the proposed agreement. The Attorney General opined that the city did not have authority to enter into the proposed agreement and that the agreement was, therefore, invalid. 1978 Ill. Att\u2019y Gen. Op. 165. Although constitutional and statutory provisions addressing intergovernmental cooperation authorized cities to contract with counties, they did not authorize cities to donate city funds to counties, which was, in essence, what the city was proposing to do. 1978 Ill. Att\u2019y Gen. Op. 165. According to the Attorney General, a home rule municipality\u2019s powers are limited to strictly local affairs and do not encompass those involving other municipalities, the county, or the State. 1978 v. Att\u2019y Gen. Op. 165. Thus, the city was under no legal obligation to assist the county in remedying the financial problems that were caused when businesses located in territory annexed by the city were no longer subject to the county\u2019s service occupation tax. 1978 Ill. Att\u2019y Gen. Op. 165.\nPlaintiffs\u2019 reliance on the foregoing Attorney General opinion is misplaced. In our view the critical distinction between the Transfer Tax and the City of Belleville\u2019s proposed arrangement with St. Clair County is the nature of the benefit received by the party collecting the tax. In this case, the City benefits from forwarding Transfer Tax revenues to the School District because better-financed schools benefit the community (which includes the portions of the School District that are within the City) as a whole. In the scheme proposed by the City of Belleville, as the Attorney General specifically noted, the county was not obligated under the agreement to pay any consideration therefor. Indeed, for sharing sales tax revenue with the county, Belle-ville received no benefit in return. Its transfer of tax revenue was purely gratuitous, which is not the case here (as we can discern from the complaint\u2019s allegations).\nFor the same reason that we reject plaintiffs reliance on the Attorney General Belleville opinion, we also reject the second aspect of plaintiffs\u2019 claim in count IV Therein, plaintiffs alleged that Transfer Tax revenues will be used to fund the School District, which includes areas outside the City\u2019s corporate boundaries and jurisdiction (because the entities\u2019 boundaries are not coterminous). They alleged that the City has no authority to pass or enforce an ordinance that has an extraterritorial effect by disbursing tax monies to the School District. In our view, plaintiffs failed to state a claim that the City exceeded its authority. Again, better-financed schools benefit the community as a whole. See, e.g., Board of Library Directors v. City of Lake Forest, 17 Ill. 2d 277, 285 (1959) (upholding statute requiring township to pay to cities the proceeds of township library tax collected on property lying within cities; fact that libraries maintained by the cities were located outside the boundaries of township did not invalidate the levy; \u201cthe true test is the enhancement of the general welfare of the township levying the tax\u201d). The allegation that there are portions of the School District that are not within the City\u2019s boundaries does not form the basis of a claim for relief.\nIn summary, we conclude that the trial court did not err in dismissing plaintiffs\u2019 claim in count IV that the City exceeded its constitutional authority.\nE. Count V \u2014 the School District\u2019s Authority\nFinally, in count V, plaintiffs asserted that the School District exceeded its constitutional authority by entering into an intergovernmental agreement for the City to collect taxes and give them to the School District and for the School District to accept the tax revenues.\nSpecifically, plaintiffs alleged that, since the Transfer Tax will be used to fund the School District, which includes areas outside the City\u2019s boundaries and jurisdiction, the Ordinance has an extraterritorial effect. An intergovernmental agreement, plaintiffs alleged, cannot be used in this manner.\nThey also alleged that the School Code and other statutes provide a complete and specific method for financing public schools. For example, the School District, under the School Code, can levy only ad valorem (i.e., according to value) taxes on real property (105 ILCS 5/17 \u2014 2 (West 2008) (\u201cThe school board of any district having a population of less than 500,000 inhabitants may levy a tax annually, at not to exceed the maximum rates and for the specified purposes, upon all the taxable property of the district at the value, as equalized or assessed by the Department of Revenue as follows\u201d)). Plaintiffs alleged that the School Code does not give the School District the authority to impose the Transfer Tax either directly or indirectly through the City and does not give the School District the authority to receive Transfer Tax revenues from the City.\nThus, in summary, plaintiffs alleged that the Intergovernmental Agreement is invalid because it has an extraterritorial effect and because the School District does not have statutory authority to impose (directly or indirectly) a transfer tax or to receive transfer tax revenues. On appeal, plaintiffs address only the statutory authority and not the extraterritorial aspect of their claim. We limit our analysis accordingly and, for the following reasons, conclude that the trial court did not err in dismissing count V\nWe begin by reviewing the powers granted to non-home-rule entities such as the School District and the authority they may exercise via intergovernmental agreements. The constitution provides that school districts \u201cshall have only powers granted by law.\u201d Ill. Const. 1970, art. VII, \u00a78. This provision preserves the concept of \u201cDillon\u2019s Rule.\u201d Under \u201cDillon\u2019s Rule,\u201d non-home-rule units possess only those powers that are specifically conveyed by the constitution or by statute or that are necessarily implicit from the express authority. Commonwealth Edison Co. v. City of Warrenville, 288 Ill. App. 3d 373, 380 (1997); Fischer v. Brombolich, 207 Ill. App. 3d 1053, 1059 (1991). Because a non-home-rule entity derives its powers only from \u201can express grant from the legislature, the statutes granting this power are strictly construed, and any doubt concerning an asserted power is resolved against the [non-home-rule entity].\u201d Fischer, 207 Ill. App. 3d at 1059.\nAs plaintiffs note, the Attorney General has, in various opinion letters, consistently opined that non-home-rule entities may not, by entering into intergovernmental agreements, circumvent statutory requirements or limitations. See, e.g., 2005 Ill. Att\u2019y Gen. Op. No. 05 \u2014 010 (\u201cthe Intergovernmental Cooperation section of the Constitution and its statutory counterpart, the Intergovernmental Cooperation Act, are not grants of authority to undertake jointly functions that the cooperating entities cannot undertake individually\u201d); 2000 Ill. Att\u2019y Gen. Op. No. 00 \u2014 015 (constitutional and statutory intergovernmental cooperation provisions \u201care not *** independent grant[s] of authority and cannot authorize an entity to do that which is not otherwise authorized or permitted by law\u201d); 1998 Ill. Att\u2019y Gen. Op. No. 98 \u2014 014 (same).\nCertain opinion letter factual scenarios are instructive. In one letter, the Attorney General opined that a public group self-insurance fund, whose members consisted of units of local government and state agencies, could (as to certain of its members) expand its coverage to provide group health insurance benefits for its members\u2019 employees and their dependents. 1998 Ill. Att\u2019y Gen. Op. No. 98 \u2014 014. Specifically, counties and home rule units could jointly self-insure the benefits, but non-home-rule municipalities did not have that authority because they did not have the independent authority to self-insure and the Intergovernmental Cooperation Act did not independently grant them authority to do so. 1998 Ill. Att\u2019y Gen. Op. No. 98 \u2014 014.\nIn another opinion, the Attorney General addressed the authority of a township (which is a non-home-rule unit) to contract with a private corporation to provide for the collection and disposal of waste and recyclables from residences within the township\u2019s unincorporated areas, as well as commercial waste generated by the township. The questions posed were whether referendum approval was a prerequisite to the exercise of such authority and whether, in the absence of referendum approval, the township could implement the plan through an intergovernmental agreement between it and the county. The Attorney General opined that (pursuant to the relevant statute) referendum approval was a prerequisite to the township\u2019s contemplated contract and that the referendum requirement could not be circumvented through the use of an intergovernmental agreement with the county. 2000 Ill. Att\u2019y Gen. Op. No. 00 \u2014 015. \u201cAn intergovernmental agreement by which the county would facilitate waste collection in a single township, without relation to waste management in surrounding areas, is not consistent with the apparent legislative intent of\u2019 a statute permitting county-wide waste management plans. 2000 Ill. Att\u2019y Gen. Op. No. 00 \u2014 015. Further, another statute that permitted counties to contract with various governmental entities for waste disposal did not specifically mention townships. 2000 Ill. Att\u2019y Gen. Op. No. 00 \u2014 015.\nFinally, in another letter, the Attorney General opined that an entity formed under an intergovernmental cooperation agreement between home rule and non-home-rule municipalities was bound by statutory limitations governing its non-home-rule members. 2005 Ill. Att\u2019y Gen. Op. No. 05 \u2014 010. Specifically, home rule members were exempt from competitive bidding statutes when seeking contractors to develop the proposed South Suburban Airport in Peotone. 2005 Ill. Att\u2019y Gen. Op. No. 05 \u2014 010. Non-home-rule municipalities had more limited powers and were subject to the State\u2019s procurement requirements. 2005 Ill. Att\u2019y Gen. Op. No. 05 \u2014 010.\nWe find the foregoing opinions well reasoned and persuasive. See Vine Street Clinic v. HealthLink, Inc., 222 Ill. 2d 276, 283 (2006) (Attorney General\u2019s well-reasoned opinions \u201cinterpreting or construing an Illinois statute are persuasive authority and are entitled to considerable weight in resolving a question of first impression, although they do not have the force and effect of law\u201d). We reject defendants\u2019 assertion that the foregoing Attorney General opinion letters are inapposite because the statutes at issue \u201cexpressly prohibited\u201d the non-home-rule entities from performing certain acts. To the contrary, the provisions at issue in the opinions did not expressly prohibit certain acts. See 2005 Ill. Att\u2019y Gen. Op. No. 05 \u2014 010 (stating that section 11 \u2014 103\u201410 of the Municipal Code (65 ILCS 5/11\u2014 103 \u2014 10 (West 2004)) allows municipalities to jointly exercise their statutory powers to operate airports, but does not, expressly or impliedly, remove the limitations imposed on them by other laws); 2000 Ill. Att\u2019y Gen. Op. No. 00 \u2014 015 (opining that article 210 of the Township Code (60 ILCS 1/210 \u2014 5 et seq. (West 1998)) expressly authorized townships, with referendum approval, to contract for waste disposal and that referendum requirement could not be circumvented through use of intergovernmental agreement with a county); 1998 Ill. Att\u2019y Gen. Op. No. 98 \u2014 014 (noting that section 10 \u2014 4\u20142 of the Illinois Municipal Code (65 ILCS 5/10 \u2014 4\u20142 (West 1996)) does not grant non-home-rule municipalities the option to self-insure, but not noting that it expressly prohibited the option).\nThus, as we have noted: (1) non-home-rule units such as the School District may exercise only those powers granted to them by the constitution or by statute, together with such implied powers as are essential, not merely convenient, to carry out their express powers; and (2) the power to cooperate intergovernmentally cannot authorize an agreement that contravenes statutory prohibitions or limitations that apply to the participating entities. In count V, plaintiffs sufficiently alleged the foregoing. They alleged that the School District, as a public school district, did not have the authority to enter into an intergovernmental agreement to enact a Transfer Tax or receive Transfer Tax revenues where the School Code does not authorize such acts.\nNext, we assess the School District\u2019s statutory authority to enact the Transfer Tax or receive Transfer Tax revenues. School boards or districts do not have an inherent power to levy taxes. In re Application of the Du Page County Collector, 294 Ill. App. 3d 868, 870 (1998). Rather, that power is granted by the legislature and is strictly construed. Du Page County Collector, 294 Ill. App. 3d at 870.\nPlaintiffs argue that they adequately pleaded that, although the City may have the authority to enact a Transfer Tax, the School District does not have independent authority to enact (directly or indirectly) such a tax to generate additional revenues. Plaintiffs assert that, like the township in the opinion letter addressing waste collection, the School District cannot circumvent the School Code or other statutes by entering into an intergovernmental agreement to receive Transfer Tax revenues when it does not have independent authority to do so. Plaintiffs argue that the School Code authorizes the School District to impose property tax levies, but not transfer taxes. Thus, an intergovernmental agreement cannot give the School District authority to receive tax revenues generated by the City\u2019s Transfer Tax.\nDefendants respond that the City and not the School District enacted the Transfer Tax pursuant to its statutory and constitutional authority and assert that plaintiffs have not provided any legal authority expressly prohibiting the distribution of Transfer Tax proceeds to the School District. They urge that plaintiffs, therefore, have failed to state a claim that the School District exceeded its authority or that the Intergovernmental Agreement is invalid. Defendants further note that section 10 \u2014 20 of the School Code grants school districts wide powers as to school matters and shows that school districts are not restricted to powers expressly enumerated in the School Code. Section 10 \u2014 20 of the School Code provides:\n\u201cThe school board has the powers enumerated in the Sections of this Article following this Section. This enumeration of powers is not exclusive, but the board may exercise all other powers not inconsistent with this Act that may be requisite or proper for the maintenance, operation, and development of any school or schools under the jurisdiction of the board. This grant of powers does not release a school board from any duty imposed upon it by this Act or any other law.\u201d (Emphasis added.) 105 ILCS 5/10 \u2014 20 (West 2008).\nSubsequent statutes address school boards\u2019 powers to, inter alla, \u201cprovide for the revenue necessary to maintain schools in their districts\u201d (105 ILCS 5/10 \u2014 20.3 (West 2008)), visit and inspect schools (105 ILCS 5/10 \u2014 20.6 (West 2008)), appoint teachers and fix their salaries (105 ILCS 5/10 \u2014 20.7 (West 2008)), and develop and implement policies of hiring minority teachers (105 ILCS 5/10 \u2014 20.7a (West 2008)). Plaintiffs respond that section 10 \u2014 20 grants school districts only incidental powers and grants them only so long as those powers do not conflict with any other state law.\nWe conclude that plaintiffs failed to state a claim that the Intergovernmental Agreement is invalid because the School District exceeded its authority in imposing (directly or indirectly) a Transfer Tax and agreeing to receive Transfer Tax revenues. We disagree with plaintiffs that this case is similar to the Attorney General opinion letter addressing waste collection. There, the Attorney General opined that a township could not circumvent a statutory limitation (i.e., referendum approval) through the use of an intergovernmental agreement. Here, in their amended complaint, plaintiffs alleged that the enactment of a transfer tax and the receipt of revenues thereunder were not consistent with, specifically, the School Code provision that specifically permits school boards to impose ad valorem taxes on real property (105 ILCS 5/17 \u2014 2 (West 2008)). Plaintiffs\u2019 complaint alleged that school districts can levy only property taxes and not transfer taxes and, thus, in the absence of specific authority to enact the Transfer Tax, the Intergovernmental Agreement is void. In our view, plaintiffs overlook the fact that the City and not the School District enacted the Transfer Tax and that none of the School Code provisions upon which they rely prohibits a school district from receiving transfer tax revenues. Accordingly, we conclude that the trial court did not err in dismissing count V\nIV CONCLUSION\nFor the foregoing reasons, the judgment of the circuit court of De Kalb County is affirmed.\nAffirmed.\nHUTCHINSON and BURKE, JJ., concur.\nRajterowski paid $1,915; the Skeltons paid $2,395; the Eliasons paid $2,425; and the Hudons paid $2,020.\nA second aspect of the right to travel is a newly arrived citizen\u2019s right to the same privileges and immunities enjoyed by other citizens of the same state. This right is identified in the privileges and immunities clause of the fourteenth amendment. Saenz, 526 U.S. at 502-03, 143 L. Ed. 2d at 703-04, 119 S. Ct. at 1526. A third aspect of the right to travel, which has no specific textual source in the constitution, protects the right of a citizen of one state to enter and leave another state. Saenz, 526 U.S. at 500-01, 143 L. Ed. 2d at 702, 119 S. Ct. at 1525. The right to travel is not explicitly mentioned in the federal constitution, and Saenz is the only Supreme Court case to enunciate three aspects of the right to travel. Further, the right to travel has, in various cases, been held to be grounded upon the privileges and immunities clause of article iy the privileges and immunities clause of the fourteenth amendment, or the commerce clause, or it has been generally considered as a basic right under the federal constitution. Shapiro v. Thompson, 394 U.S. 618, 630 n.8, 22 L. Ed. 2d 600, 612 n.8, 89 S. Ct. 1322, 1329 n.8 (1969) (citing cases), overruled on other grounds by Edelman v. Jordan, 415 U.S. 651, 39 L. Ed. 2d 662, 94 S. Ct. 1347 (1974).\nPIaintiffs also alleged (generally and not as to any specific plaintiff in this case) that parts of the City do not lie within the School District; rather, they lie in a neighboring district. Plaintiffs alleged that purchasers moving into portions of the City that are not within the School District must pay the tax even though their children will attend school in another school district.\nThe question was certified under Supreme Court Rule 308 (134 Ill. 2d R. 308).\nThe Ball court relied on Nordlinger v. Hahn, 505 U.S. 1,120 L. Ed. 2d 1, 112 S. Ct. 2326 (1992), wherein the Supreme Court addressed an equal protection challenge (without a right-to-travel component) to a California law requiring property reassessment upon a change in ownership. The law exempted from reassessment property transfers by persons over age 55 and transfers between parents and their children. The Ball court noted that the Court upheld the exemptions, concluding that a \u201c \u2018[sjtate has a legitimate interest in local neighborhood preservation, continuity, and stability.\u2019 \u201d Ball, 281 Ill. App. 3d at 684, quoting Nordlinger, 505 U.S. at 12, 120 L. Ed. 2d at 13, 112 S. Ct. at 2333.\nThe term \u201cpublic agency\u201d includes units of local government and school districts. 5 ILCS 220/2 (West 2008).\nAs an example, plaintiffs specifically referred in their complaint to the Local Government Distributive Fund established in the State Revenue Sharing Act (30 ILCS 115/0.1 et seq. (West 2008)), which requires the Treasurer to allocate to a special fund certain income tax revenues and pay therefrom certain amounts to municipalities and counties. 30 ILCS 115/1 (West 2008). Municipalities and counties must use such funds \u201csolely for the general welfare of the people of the State of Illinois, including financial assistance to school districts, any part of which lie within the municipality or county, through unrestricted block grants for school purposes carried out within the municipality or county making the grant\u201d (30 ILCS 115/3 (West 2008)).\nAs to the park district, the court held that the ordinances did not constitute unauthorized regulation, because municipalities had explicit statutory authority to establish and maintain parks. City of Peoria, 76 Ill. 2d at 477.\nTechnically, although they did allege that the School District is a public school district that exceeded its constitutional authority, plaintiffs did not specifically allege that the School District is a non-home-rule entity. Elsewhere in their complaint, they alleged that the City is a home rule unit. We do not find plaintiffs\u2019 failure to specifically allege that the School District is a non-home-rule entity fatal to their claim.", "type": "majority", "author": "JUSTICE JORGENSEN" } ], "attorneys": [ "David A. Rolf, Todd M. Turner, and Lisa A. Fetrilli, all of Sorling, Northrup, Hanna, Cullen & Cochran, Ltd., of Springfield, for appellants.", "Keith L. Foster, Kevin E. Buick, and Timothy J. Conklin, all of Foster & Buick Law Group, LLC, of Sycamore, for appellee City of Sycamore.", "Kenneth M. Florey, Nanci N. Rogers, and Scott L. Ginsburg, all of Robbins, Schwartz, Nicholas, Lifton & Taylor, Ltd., of Chicago, for appellee Sycamore Community Unit School District No. 427." ], "corrections": "", "head_matter": "MICHAEL A. RAJTEROWSKI et al., Plaintiffs-Appellants, v. THE CITY OF SYCAMORE et al., Defendants-Appellees.\nSecond District\nNo. 2\u201409\u20141136\nOpinion filed November 1, 2010.\nDavid A. Rolf, Todd M. Turner, and Lisa A. Fetrilli, all of Sorling, Northrup, Hanna, Cullen & Cochran, Ltd., of Springfield, for appellants.\nKeith L. Foster, Kevin E. Buick, and Timothy J. Conklin, all of Foster & Buick Law Group, LLC, of Sycamore, for appellee City of Sycamore.\nKenneth M. Florey, Nanci N. Rogers, and Scott L. Ginsburg, all of Robbins, Schwartz, Nicholas, Lifton & Taylor, Ltd., of Chicago, for appellee Sycamore Community Unit School District No. 427." }, "file_name": "1086-01", "first_page_order": 1102, "last_page_order": 1139 }