peace officers or brain surgeons they're still correctional deputies i think if that's their primary function i would argue that the juvenile detention facility in every valley is is as much of a jail is any county facility there is pictures were submitted if you can score in that part of the room they are housed in cement block cells with cement block beds and bulletproof glass with bars on it with steel reinforced doors they are transported in handcuffs w supervisor do their work there will times and we are there to monitor housed and safely control juveniles who are a danger to themselves or to the community but we spend a lot of time talking about what is  are almost a mirror image but when you look at the inside and you look at the word correctional facility and you look at what is housed inside of the will copy of the river valley detention facility you'll see the exact a thing there are central control or video attention facility it's not called the jail and i don't think there's anybody from who would who would deny it is a correctional facility but why is it a correctional correctional facility and the juveniles are not when they operate in the exact same manner the interstate correctional compact and has no broader application code when we use the word inane and these have to be defined as in if they get to the next step which is this is a correctional facility the board says the dictionary definition is fine decision to shift supervisors the supervision and control over the next step they easily found that they were supervising the control that they now defined to be inmates because of a dictionary definition but apparently the word in me is much easier to define correctional because when they got to correctional the first thing you say is the board has never addressed what factors renders official a correctional facility under the act there were no law but it seems to me that the well there aren't but the problem is there that there are numerous statutory definitions and the river valley detention facility falls into probably more than half of a facility to how those inmates and to protect the public and themselves from why aren't you at the way relations at least said under security employ a correction facility it's simply generically says a correctional facility a place which restricts the freedom of an inmate which we know is rock solid definition here and construing its own statute to determine that no term of art was intended that the corrections definition is the proper one and that there is no need to resort to dictionaries or other outside sources to figure out what that means and as it happens there's also a statutory definition for detention staff such as the staff at river valley they are included in the definition of probation officers in the probation act the general assembly knows how to designate something in a particular way when it wants to and if it had intended for detention staff to be included discretion officers it could have done so explicitly it did it designated them as probation officers juvenile detention is not correct illinois lawmakers have supplied a definition of detention as a place of temporary here for minors for their own protection or the protection of the community and these definitions and distinctions are reasonable policy choices for the legislature to have made and statutory definitions control but even though there is no functional equivalency test no walks like a duck quacks like a duck test for what isn't attention center if you actually look through this record and you examine the duties of the staff at river valley it's still not a correctional facility because the stats function which is explicit in their job descriptions in the testimony about what they do day in day out every day the river valley manual and the illinois administrative code it all points to the staff is there to see to these kids emotional and physical needs this is a staff that delivers supervision and here not correction not punishment no screwing if they were to walk out on strike would the effect at the detention center be the same as if the correctional officers were destroyed at a correctional facility i'm not sure what the effect would be for a correctional facility where i know is that we're not talking first of all about thirty nine people who deliver the hands on day to guess i'm i'm coming from a little different direction and thinking that the interest of interest arbitration yes the purpose of that is to avoid having people striking where the effect of their striking him here is the security security the place where they're working and safety as far as i can tell these people have the right to strike because it's something that they offered to give up in exchange for getting interest arbitration and if they were to strike there are provisions in the labor act for the board to investigate to make sure that there are no us there would not be any compromise of security no risk to the general public health and safety and you have those same provisions for correctional facilities that i'm not in that  they are part of their own union they are not in this i do not believe that they are on the scene as the thirty nine pants on here getting staff members there it's different there's not a functional equivalency tested statutory definition that controls here but just one more quick question i'm sorry if the definition of correctional facility that you're using is the definition from the statute the code of corrections  and that's saying essentially for purposes of this statute a correctional facility is defined as this as this what is it that makes that definition in that statu translatable to another statute that merely talks generically about correctional facility without saying as the find anywhere to the extent that the subject matter has places where people are confined then the statutes must be read in harmony with each other we have the definition in the one place we don't need to redefine it or repeat it in another when we have a perfectly serviceable definition we read these two statutes together and one last point i wanted to make about education life skills something is struck me in reading the record river valley manual points out that a lot of the kids who come through have never seen or even participated only mystery to good mandates that these kids while in detention receive instruction in basic life skills that many of us will take for granted like how to clean a kitchen how to clean a backing how to have heat and sells heat and it is the mission of afternoon please a court the issue before you today is one of the board correctly determined that river valley supervisors are not security employees because river valley is not a correctional facility and we heard today from  from the petition arguments that we've heard throughout this process and they seem to be truthful one is that the river valley you know the tension itself is just like the will county  s let me address first the argument and it seems to be the argument that all the evidence that the vast majority of the evidence that has not been in the right address but there are two key pieces of evidence that the adult attention facility that may have similar where may have similar rooms may have similar bolts and tables may have similar ping pong tables all these arguments that have been made but nowhere in the record is there any  or any support that the will county adult attention facility is a correctional facility as dissipated by the state labor relations board or the legislature in the final state labor relations and in  position of the petition for employees should be treated just like the correctional officers at that well kind of job nowhere in iraq is there any yet that the officers that work there will county adult since facility have ever been  dictionary definition by the us legal doctrine they've ignored the fact that there are other definitions that can be found on line for other dictionary such as dictionary dot com or black's law dictionary that maybe aren't quite a correctional or is it not a correctional facility it ignores that the administrative office of the courts probation and court services division does not consider real river valley to be a correctional facility  american correctional association does not consider river valley to be a correctional facility and instead it says you should rely on us legal dot com they're the authority that is courts rely on determine whether or not the river valley is a correctional facility but that definition even by that definition petitioner's case fails in part the us legal dot com definition is that a correctional facility is quote a term that it's not a mutually exclusive definition and maybe you there could be other facilities that meet that initially could finally be called by a different name for example you could have a situation where a mentally ill individual has been those psychiatric facilities are then become a correctional facility even if also their second under the u s legal dot com definition and requires incarceration heard petitioner here today say these that these are murderers these are buying criminals they of course they've got to be kept in a jail course they've got to be kept in a correctional facility these people not you they're innocent they're innocent til for certain very limited categories or i'm of toys that are automatically that night the right to strike one of those categories being security employees and over and over again the labor board has narrowly construed those definitions to broadly interpret the a question of what would happen if these individuals went on strike would that be the same as what would happen with correctional officers but we don't know there's no evidence in the record but and say it then if you with these eleven supervisor he supervisors seven of which are in charge with supervising juvenile detention officers who have to direct supervision over the juveniles four of them are more if the chief judge truly believe that those individuals going out on strike there's a process in the statute that allows the chief judge to address and that's under section eighteen at this stage which would allow the chief judge to petition the labor board and to make their case on an individual case by case basis on why if this individual is allowed to go out on strike how then we create clear and present danger to the public if the labor board then agrees and a broad stroke they have looked at it and if you have a whole category of employees for instance of one of the leading cases of labor board is involved the city of naperville and their electrical workers because the city employees provide electrical services and next days the city actually sought to prevent a large group of electrical linemen from strike saying that of course of the power goes out and we don't have anyone here to you to correct the issue that poses a clear and present danger to the public the labor board instead of saying all of these individuals are the food of the strike you indicated earlier no that only a small amount think five of the total could be prohibited from striking and even then could they only be prohibited in an emergency situation that the city cannot keep them quiet or prevent them from striking just to maintain the lines so it's not a situation where you know we need t probably drug users all the patients want to go back out there and it's happened we've had judges release your mouse will go on a killer pair of these that that's the intent of the statute you know when when mr bennett came up and said ah they forgot to charge of maintaining the security of this facility go on strike the facility is at risk of the people around it are at risk just like communities that don't want prisons in their community it's for that reason so on the the idea of of these were cheeses sometimes you know you give me you mentioned mr justice how different things are now as they were then well we used to call a divorce now it's called dissolution and we used to call it alimony family up and get the same the same result is there no matter what you call for this idea of going to the links to say we have to look at this jack we have to look at this yet why it's called a correctional facility you know looking out from a simple wave this is a very narrow case about whether or not security employees with the meaning of section three exactly isn't the right arbitrat