CTA Transit Enforcement Audit

Peak Year ANOVs

18,040

2025 - all-time high

Baseline ANOVs

4,189

2022 - pre-surge

ANOV Increase 2022→2025

+331%

in three years

Board Auth. Overspend

$26M

Retroactively approved Oct 2024

Total ANOVs by Year

The Core Finding

The CTA spent approximately $251 million on private security contracts while the Department of Administrative Hearings produced $2,669,348 in total fare evasion fines - less than one percent of contract cost. 65% of that fine revenue came from automatic $300 default judgments against defendants who did not appear. Of the cases actually contested, the city failed to establish a prima facie case in 1,092 instances. The enforcement system's primary output is not fare compliance or revenue - it is default judgments against people who cannot navigate an administrative hearing process. Department of Finance collection records (May 4, 2026) show only $26,148.57 was actually collected in cash from fare evasion - 0.98% of fines assessed.

ANOVs by Violation Category - 2018 to 2025

Key Finding

Smoking is the single largest enforcement category in every year on record. In 2025: 4,364 smoking citations versus 2,475 fare evasion citations. Fare evasion has consistently represented 8–14% of total ANOVs. If the fiscal argument for the $251M private security apparatus is fare revenue recovery, the citation composition does not support it - and the DOAH adjudication data now confirms the revenue was $2.67M.

2022 Arrests

410

pre-surge baseline

2024 Arrests

1,820

peak - +344% vs 2022

"Other" Share, 2024

77%

of all arrests - undefined category

Arrests by Charge Category

Critical Anomaly - Confirmed by DOAH Data

The "Other" arrest category - undefined in CPD's FOIA response - grew from 258 (2022) to 1,404 (2024), a 444% increase. The DOAH adjudication data corroborates this: the city filed motions to amend the charge in 1,904 of 11,043 cases - nearly 1 in 6. Officers appear to be writing citations under charge codes that cannot survive adjudication as written. What the "Other" category contains, and who authorized its use, remains officially unanswered.

Fare Evasion: Count and Share of Total ANOVs

Fare Evasion Citations by Year

The ROI Problem - Now Quantified

Fare evasion has hovered at 8–14% of all ANOVs across the entire period. DOAH adjudication data now closes the revenue loop: 11,043 fare evasion cases produced $2,669,348 in total assessed fines - against $251M in private security contracts. Even accepting every default judgment at face value, the system returned less than one cent for every dollar spent on enforcement infrastructure. Department of Finance collection records produced May 4, 2026 now show what was actually collected in cash: $26,148.57 - 0.98% of fines assessed. See the Adjudication tab for the complete collection picture.

Unique Cases - DOAH

11,043

Fare evasion cases adjudicated · all years

Total Fines Assessed

$2.67M

Assessed by DOAH · $26,148.57 actually collected in cash

Default Judgments

65%

Defendants who never appeared - auto $300

Charge Amendments

1,904

City had to change the charge - nearly 1 in 6

Disposition Breakdown - All 11,043 Cases

Full Disposition Table

Disposition	Cases	Fine	% of Total
Default - Liable by prove-up (defendant no-show)	8,456	$300	65%
City's motion to amend the charge - Granted	1,904	$0 / varied	15%
Not liable - City failed to establish prima facie case (city lost outright)	1,092	$0	8%
Liable - By plea	587	$50	5%
City non-suit (city dropped case)	488	$0	4%
Liable - Prepaid / contested / other	516	varied	4%

The Default Judgment Machine

People who showed up to their hearing had a meaningful chance of winning. The city could not prove its case in 1,092 contested proceedings - roughly one in six contested cases. It also had to amend the charge it was bringing in nearly one in six cases overall. But most defendants did not show up. They received automatic $300 default judgments with no one to argue that the city couldn't prove its case. The enforcement system's primary function, as documented by this data, is generating default judgments against people who cannot navigate a hearing process to contest a $300 fine.

Termination Anomaly - April 18, 2026

The CTA terminated the Monterrey Security contract on April 18, 2026 - approximately three weeks after executing an affirmative one-year renewal through April 3, 2027. The termination reason cited: non-appropriation of funds. Contract renewals are not automatic. The same CTA purchasing agent (GM of Purchasing) who processed the original contracts also processed the renewal. No budget crisis was publicly declared in the intervening three weeks. The sequence has no routine procurement explanation.

Contract Record - CTA Private Security · 2021–2025

Monterrey Security Consultants

B21OP04714 · Buyer: Linares, Iliana

$44,307,824

Primary contract. Buyer: Iliana Linares (GM of Purchasing). Same buyer, same day as Inter-Con contract.

Monterrey Security - Supplemental

B21OP04714B

$3,000,000

Supplemental to primary contract.

Monterrey - Emergency (June 2021)

No ordinance found in 021-049 through 021-075

$3,000,000

Emergency procurement - no board vote found. Executed administratively. Relationship to subsequent $44M contract pending FOIA.

Inter-Con Security Systems

B21OP04714A · Buyer: Linares, Iliana

$56,250,000

Same day, same buyer as Monterrey primary contract.

Action K-9 Security Services

B22OP80021 · Aug 2022

$55,000,000

Aug 2022 contract.

Action K-9 Security Services

B23OP80021 · Feb 5, 2025

$89,600,000

Signed Feb 5, 2025 - 10 months before the FTA pressure campaign began following the Dec 2025 Blue Line fire.

Board Authorization Gap

Ord. 022-034 Authorized

$71M

Mar 9, 2022 · unanimous 6-0 · Monterrey + Inter-Con combined

Actual Contract Value

$97M

Monterrey + Inter-Con combined at execution

Retroactive Approval

Oct 2024

Ord. 024-140 · $26M overspend ratified 2.5 years later

Monterrey Background

Contractor Profile

Juan Gaytan (founder) - CPD officer, resigned 2002 following 15-month suspension. City settled federal lawsuit related to his conduct for $95,000.

Santiago Solis (co-founder) - brother of Danny Solis, 25th Ward alderman who pleaded guilty to federal corruption charges in 2023.

Executive roster: Anthony Riccio (former CPD Chief of Patrol), Fred Waller (former CPD Area Central commander), Hiram Grau (former Illinois State Police director).

Prior record: $2.9M city contract rescinded following ethics violation finding. FBI investigation into no-bid Rosemont contract.

Campaign contributions: Gaytan + Monterrey combined - $306,621 across 255 transactions. George Cardenas (Transportation Committee Chair, CTA oversight): $3,500 in 2025 while contract active. Mayor Brandon Johnson: $3,000 (July 2023). Most recent contribution: $1,750 to Rosemont Voters League, March 13, 2026 - five weeks before termination.

Consultation Pattern - Documented in Statutory Record

Three of five original agencies - Department of Finance, Cook County Sheriff, and the CTA - each invoked the identical 5 ILCS 140/3(e) consultation extension, citing need to consult another public body, within eight days of each other, on requests filed the same day. The Mayor's Office, responding to a later request, invoked a different extension (undue burden) and notably did not check the consultation box. 15 active FOIAs and 5 PAC appeals across federal, state, and municipal agencies.