manner this is a case about the city of sparta's activity points system that does not require officers to write a specific number of citations but it does give credit to an officer who writes a ticket in the city's activity points system to basically the officers performance evaluation system so the issue before this court is whether the city of start a system in indirectly whether many other systems across the state that are similar violates what is commonly known as the illinois quota act basically whether the quota act prohibits something other disagree and asked this court to reverse the judgment of the court so let me talk just briefly about the facts i mean since we are here on quest motions for summary judgment they really aren't in dispute but i think there are a few that are important this system dates to two thousand and thirteen prior to two thousand and fifteen when the quota act was enacted the purpose of the activity point systems is to ensure that officers are busy doing the work that they were hired to do each week patrol officers activities in the form of investigatory activity patrol activity community related activities are tracked and then officers are assigned points for activities that ball within those essential functions of an officer so it could be pulling someone over it could be working in non criminal case it could be working on an investor could investigatory case it could be a traffic stop it could be writing writing a warning and then of course because enforcement is part of an integral constant of an officer an officer could receive points if the officer in his good discretion determined to write a ticket at the end of the month those points are totaled and to see whether the officer met the officers points that have been pretty determined again though none of these points are broken now there is no whether it's credit for citations it is really undisputed here that anybody is required to write a specific number of citations or whether it be appraised terming number or a number that's determined by looking at another officers points so there is no one specific number no comparison and undisputed that officers decide to use their discretion about whether they want to write a ticket officers decide how they get their points they can get their points by doing any number of other activities and in fact in this particular case officers of this department have unpacked met their points by doing other activities other than citations so just turning again to this case this is case of st impression and it is the case that will not only affect the city of sparta but will indirectly perhaps directly affect undisputed that the case and the review is to know the appellate court in this case by focusing on one particular provision of again what we're calling the code to act determined that the language was clear in determined that any consideration of quotas whatsoever regardless of whether or not they were officers were required to write a certain number was somehow in permissible however that construction turns both the language of the statute as well as the legislative history on its head contrary to the appellate court argument into susan whether you look determine the language is clear and look at the clear language only or whether you would consider extrinsic evidence in the form of legislative debates the city's position that quota act only prohibits quotas must prevail  here so let's talk a little bit about the clear language of the statute if we might according to the principles of statutory construction this statute must be read as a home and not one sentence in isolation and all that must be read in a way that all provisions are given a fact so if you look at the quota act there are basically four different sentences that focus on one unwind what is prohibited as well as what is permitted under the act so in order to determine the legislative intent and whether it's clear or not all of those provisions must be read as a whole and when you do that that leads to only inescapable conclusion and that that is that all the legislature intended to prohibit were quote they were intending to prohibit a department from saying officer a you have to write ten tickets today or officer b you have to write five tickets today they were not trying to do anything more and the reason that they were doing this is because there had been concerns about whether office or whether departments were imposing quote as a supporter of raising revenue to the negative impact on officer discretion so they wanted to emphasize officer discretion to choose to write tickets not to an officer to write a specific number of citations within a specific period of time it also goes on to say that that same municipality may not compare the number of citations that an officer writes to the specific number of citations that another officer writes so that is prohibitory language then in more permissive language obviously intended to distinguish the group the prohibited conduct in the st two sentences from the permissible language the statute sates nothing in the sex and so prohibit a municipality from evaluating an officer based on the police officers points of contact and then it goes on to define what points of contact are finally in a further effort to clarify what is permissible versus and permissible the statute goes on to explain that the pontiff i have full points of contact obviously a reference to the rd sentence do citations or the number of citations issued by a police officer so here if you read the sentences as a whole starting with the section heading which is actually called quotas prohibited and then you read those four sentences together it basically the to the n escapable conclusion that employers may not require an officer to write a specific number of citations within a specific period of time or compare the number of citations that one officer writes to excuse me to another officer but that that  impose such a requirement and evaluate an officer based on other points of contact as long as those quantifiable contacts do not include a requirement that an officer wri a specific number of tickets or is to a specific number of tickets so by way of example a department could say for example right you have to write thirty traffic you have to make thirty traffic stops you have to make ten arrests or you have to have fifty activity points total but what it can't say is that in the course of that  tips ten of those matters and ten of those activities need to be writing techniques and that's really all this dance this interpretation the one that i just laid out for you not only reads all the provision of the statute in concert doesn't leave any out but it also gives effect to the legislative history and to this the heading of the s f we talk about reading these together to give a fact to all of these provisions it leads also to the conclusion that this is an interpretation that mirrors or matches what is the commonly understood definition of a quota and if think we all understand that a quota is we're crying somebody to do a certain amount of work and that's what was intended here in the section headings says quotas prohibited so reading at this way that's the result we get also if we consider the fact that if the legislature had intended to prohibit the consideration of citations at all it obviously could have adopted a statute that says you can't you can't look at whether an officer right seconds or if you can't consider tickets at all in any kind of a valuation system that would have been a much simpler way  us but the legislature didn't do that so we cannot assume that that's what they intended and it's also are a reflection that the interpretation of the appellate court did not match that of the legislative intent and was correct that the quota act or that a city can violate the quota act before sentence of the quota act by just allowing citations to be given some consideration at all then one has to ask well what meaningless those st two sentences and obviously that's not what the legislature intended there's really no coherent way to honor the statutory principles and when we look at the decision of the appellate court or the interpretation dance by the union i think as significantly the use interpretation would really lead to an absurd result here assuming for argument's sake that officers could not receive any credit at all for the if there were any activities associated with writing kept its officers would actually be penalize them for writing so writing a ticket is obviously wor consuming then chest pulling someone over making a stop and i'm sure most of us have received a traffic ticket at some point or another and we know if we get off with a warning then the officer gets to go home early or if we  while it gets written up so writing a ticket is more time consuming however according to the union's theory an officer who uses his good judgment to issue a ticket would receive no credit no points or activity for the activity of writing the citation so this is an excuse me not good for the officers i put for the department it's not good for the public at large this would create a disincentive for officers to do their jobs and write tickets to citizens who to serve them officers who still decide to great tickets would have to do even more activities in order to get the same amount of points or if the disincentive works then every senate assistants who actually deserve check it send order to promote good law abiding behavior might not be getting them and if we are not engaging in force and activities then there is no incentive for people not to erv incentive for people to a bagel of which might lead to more violations made lead to more accidents and on and on so this is very real potential result is clearly very far removed from the concept of a quota system and the att added together to create points of contact and so the system compares points of contact during the month to the required number of points of contact in the system do the points according to their include issuance likely they do include the issuance of citations however there is not a specific number of citations that is required nor does the a value w who is saying that this officer had sixty five points of contact this month compared to the sixty five that are required to offer that the person doing the evaluation does not know what number of those if panning and it could be nine are based on right in but when you read the statute you have to look at it to say you the st two sentences don't just say you can't require citations for you can't compare they can't require a specific number of citations in a set period of time however you can require an officer to do other things and then that last sentence really relates back to the st two sentences which says this is them permissible this is permissible but oh by the way remember that this is not in permissible there is nothing in the stand today that says that you can't consider citations at all if basically says you can't base a evaluation system online those requirements on those effectuate the legislative intent however we all know that sometimes these things get rust and sometimes the legislature may not say things as clearly as they intended them on here court in the union has offered another interpretation to the extent that you think that both of those are reasonable conclusions then obviously the principles of statutory construction allow you extrinsic evidence comes in the form of significant very significant legislative debate and if you look at that legislative debate it is very clear what the legislature intended there are significant comments numerous comments by both the house and the senate sponsors that suggest that all this act was intending to do was to prohibit quote us nothing else so just how sponsor hofmann says as long as the department does not require a ticket quota or compare officers this bill will not affect them the he goes on to say the only thing the bill prohibits is were occurring and i was there to issue a specific number of traffic citations in a designated period of time he further says if a ticket should be written a ticket should be written but we wouldn't say  nonetheless the city argues on page fifteen of its original brief that municipalities retain authority to count citations written as a point of contact the issue in this case is therefore can the city do what the law expressly prohibits this is not a close question additionally it's worth noting that there is no argument from the city that the law is city is not asking this court to strike the law down instead its position is that the law as written does not prohibit but instead permits its points of this matter involves a complaint for declaratory judgment that complaint the nd amended complaint alleges the city city policy as implemented interpreted or applied conflicted with the act and therefore violated the policy requires full time officers to meet the points minimum on a monthly basis the point system is an evaluation policy was two words appear the bottom of page twelve of the words two points for issuing a citation dayshift officers must accumulate eighty two dollars points per month night shift officers must be late sixty five dollars points per month these thresholds are the product of averages on the respect ships that's important for the state's reference to comparison this failure to reach the point totals each month results in discipline that is the undisputed city policy issue in this case furthermore in page nineteen of its original brief the city stated that the department count citations if an officer writes on page six of its reply brief the city stated that it compares officers on the basis of cumulative activity points applying those facts to the law at issue establishes the summary judgment for the union was proper it is beyond dispute that the city policy violates the law as it is taishan don't know that we'd be here the problem is that their activity points system includes rather than execute the practice of you issuing a citation cities are given as well you know these officers spent time more time writing a ticket  the city has made the argument that the appellate court notified the laws st paragraph that claim lacks marriage because the facts in this case written policy the issue is an activity point system that's not what the law's st paragraph is about it's about a different type of system so it was no fault of the appellate court that they didn't spend a long time in the st p city's argument is essentially that because it did not violate the st paragraph it could not violated nd paragraph and that's not proper logic doesn't forbid any points of contact systems but instead only forbids including citations in the city's theory of what the law should be is essentially an appeal to the sport to change the text of the law it wants the court to either take things out of the statute or at things to them to suit purposes here there's no doubt what the law means and the city has no doubt about what the law means on page seventeen of its original brief about the middle of the page the city stated that evaluating a police officer based on points of contact which includes any quantifiable contact is permissible except as provided in the final sentence and counsel for the city made a similar state similar statement here more but that's that's one possible explanation but i think i think what that means is they tried to issue a citation it was a protected or there might have been some issue with the citation itself  would in theory the officer still get credit for going to the effort of writing say taishan even though it may not have ended up to be a number that can be counted later on i've kind of wondered about that too but this case definitely involves the number of different it could be both i don't know that or is the the proper word to use there as i'm speaking now i could be more clear i'm sure the legislature could always be we're clear in what it says but i think that's what that reference the last sentence includes the exception you cannot include the issuance of citations with the number of citations issued so that's that's really what they violated but it's not violated say here just briefly your honour's counsel for the union was asked about the enter potations of the th paragraph of the act at issue here and he was for him to at the same time argue that the statute is an ambiguous when he can't sit here and tell this court what the th sentence means as part of that same questioning terminology issues because it relates back to the st two paragraphs that base or st two sentences which use basically that a general language so we have the prohibitions these points of contact are permissible to evaluate evaluate an officer or evaluation systems based on points contact or permissible however when you read the poorest sentence in conjunction with that it basically says then that evaluation systems based on the issuance of citations are based on the number of citations are not permissible the city of sparta's system number of points that an officer receives under the city of sparta system officers receive more points or no more time consuming activity and many of the activities in th that are reference pacifically in the act officers receive one point for a citation has been awarded two points because there's some more time consuming activity you will note that a review of the evaluation system also considers  other activities that aren't specifically mentioned and those activities may also receive enhanced points just because of the length of the time so the system is not intended to in any way and sent to pie the writing of tickets it is intended to reward or credit officers for the amount of time expended in certain activities  i would just note also that the union here today has not proffered or suggested any interpretation to this court that would give a fact to all the provisions of the statute together and again for that reason we believe that the city center petition with or without the use of extrinsic evidence is the more reasonable and the