Gruwell v. The Illinois Department of Financial and Professional Regulation 

IDPR adopted finding of Real Estate Disciplinary Board that Plaintiff had engaged in the unlicensed practice of real estate in violation of Real Estate License Act, and imposed a civil fine of $25,000. Plaintiff had worked as independent contractor for Central Illinois For Sale By Owner, which operated a web site hosting classified ads for a flat fee. Plaintiff's statements, in some ads, that she was not a real estate agent did not negate her conduct in holding herself out as an intermediary between seller and prospective buyers, and as listing homes for sale. The Act exempts parties to real estate transactions from licensing requirements when acting in their own behalf; this is to be interpreted narrowly, and does not include an agency requirement. Plaintiff's receipt of commission for each ad she sold, in connection with which she performed licensed activities, is sufficient to be "for compensation" as prohibited by the Act. Fine is overly harsh, considering that Central FSBO was fined $7500 for its violations, thus is reduced to $7500. (TURNER, concurring; APPLETON, dissenting.)