Harrisburg-Raleigh Airport Authority v. Department of Revenue

In Harrisburg-Raleigh Airport Authority v. Department of Revenue, 126 Ill. 2d 326, 533 N.E.2d 1072, 127 Ill. Dec. 944 (1989), the supreme court extended the "date of mailing" rule to notices of appeal filed in the circuit court pursuant to Supreme Court Rule 303(a) (210 Ill. 2d R. 303(a)). In that case, the court reviewed the language of Rule 373 as evidence of "a general policy of equating mailing and filing dates," and ultimately held that notices of appeal mailed within the 30-day period prescribed by Rule 303(a) and received thereafter are considered timely filed. Harrisburg-Raleigh, 126 Ill. 2d at 340-41. The court concluded by stating that it "expressed no opinion as to whether the same pro-mailing policy would apply to other papers filed in the circuit court, such as post-trial motions." Harrisburg-Raleigh, 126 Ill. 2d at 342.