Bill Boies was mentioned in the August issue of Corporate Legal Times in regard to representing the Illinois Clean Energy Community Foundation (ICECF). The ICECF was ordered to pay the state of Illinois $125 million after the Illinois legislature amended the state utilities act and directed the private foundations to hand over the money to help close the state's huge budget gap. The foundation immediately sought a declaratory judgment in federal court that the state's action was an unconstitutional taking of property without compensation and a violation of due process. In April 2004, federal district court Judge Amy St. Eve agreed with ICECF and rejected the state's argument that the $ 125 million belonged to the state and that the foundation was a public entity. She agreed with the foundation that the state was attempting to take private property without compensation, in clear violation of Fifth Amendment rights.