The question was simple enough. Does the Chicago Transit Authority's fare enforcement program generate enough revenue to justify what it costs? That question led to a procurement record, a FOIA request, a dataset of 11,043 adjudication cases, and a contractor whose co-founder is the brother of a convicted corrupt alderman.
The short answer: the entire administrative and adjudication output of CTA fare enforcement - every fine assessed, every default judgment entered, every case that went through the Department of Administrative Hearings - produced $2,669,348 in assessed fines - of which $26,148.57 was actually collected in cash. In the same period, the CTA spent approximately $251 million on three private security contracts. The return on the enforcement apparatus - measured in actual cash collected - is less than one tenth of one percent of its cost.
That arithmetic is not the whole story. The whole story is what the money went to, who got it, who authorized it, and what happened when the board tried to clean up the mess two and a half years later.
The Contracts
What the procurement record shows
Three contracts account for the bulk of the CTA's private security spending. Monterrey Security Consultants received contract B21OP04714 for $44,307,824, followed by a supplemental B21OP04714B for an additional $3 million. Inter-Con Security received contract B21OP04714A for $56,250,000. Both contracts were executed the same day by the same CTA purchasing agent. Action K-9 Security Services received contract B22OP80021 for $55 million in August 2022, and contract B23OP80021 for $89.6 million in February 2025 - ten months before the FTA pressure campaign began in December 2025 following the Blue Line fire.
The combined contract values approach $251 million. The combined fine revenue from DOAH adjudication of fare evasion cases: $26,148.57.
The CTA's entire fare enforcement adjudication output - 11,043 cases processed through the Department of Administrative Hearings - produced $2,669,348 in assessed fines. The three private security contracts it was meant to justify cost approximately $251 million. Fine revenue is less than one percent of contract cost. This is not a rounding error. It is the answer to the original question.
The Board Authorization Gap
What the board voted for, and what was actually spent
On March 9, 2022, the CTA board voted on Ordinance 022-034, authorizing the Monterrey and Inter-Con contracts. The board vote was unanimous, 6-0. The combined authorized amount: $71 million. The contracts were executed at a combined $97 million - $26 million over what the board approved.
The overspend began almost immediately. Ordinance 024-140, passed October 9, 2024 - two and a half years after the contracts were executed - retroactively authorized the additional $26 million. The ordinance language acknowledged what had happened: deployments had been "significantly increased" almost immediately upon contract execution, beyond what the original authorization covered.
A Change Order No. 1 existed but did not authorize additional funding. The details of that change order remain under FOIA review.
"Almost immediately upon execution, deployments were significantly increased." - CTA Board Ordinance 024-140, October 9, 2024, retroactively authorizing $26 million in spending that had already occurred.
The June 2021 emergency Monterrey contract - $3 million - does not appear in any board ordinance from that period. A review of ordinances 021-049 through 021-075 produced no record of board authorization. That contract appears to have been executed administratively, under emergency authority, without a board vote. FOIAs for the emergency justification and the relationship to the subsequent $44 million contract are pending.
The Default Judgment Machine
What the DOAH adjudication data shows
The Department of Administrative Hearings produced 11,043 unique fare evasion cases under FOIA H135833-041326. The dataset covers the complete adjudication record for charge code 10-8-526/016-110-1.27(4): trespass by entering without paying the required fare.
65% of all dispositions were default judgments of $300 entered against defendants who did not appear at their hearing. Of the cases that were actually contested - where a defendant showed up - the city failed to establish a prima facie case in 1,092 instances. An administrative law judge ruled, in each of those cases, that the city could not meet even the basic burden of proof.
The 1,904 charge amendment entries are structurally significant. In nearly one in six contested cases, the city arrived at the hearing and had to change what it was charging the defendant with. That pattern is consistent with the undefined "Other" arrest category in CPD data - a category that grew 444% between 2022 and 2024 and accounts for 77% of all 2024 CTA Transit Section arrests. Officers appear to be writing citations under a charge code that cannot survive adjudication as written.
The equity dimension of this data is direct. People who appeared at their hearings had a meaningful chance of winning. The city could not prove its case in roughly one in six contested proceedings. But most defendants did not appear. They received automatic $300 default judgments. 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 to contest a $300 fine.
Monterrey: The Contractor
Who received $47 million in CTA public funds
Monterrey Security Consultants was founded by Juan Gaytan, a former Chicago Police Department officer who resigned in 2002 following a 15-month suspension. The city of Chicago settled a federal lawsuit related to his conduct for $95,000. Monterrey's co-founder is Santiago Solis, the brother of Danny Solis, the 25th Ward alderman who pleaded guilty to federal corruption charges in 2023.
The company's executive roster includes Anthony Riccio, former CPD Chief of Patrol; Fred Waller, former CPD Area Central commander; and Hiram Grau, former Illinois State Police director. Prior to the CTA contracts, Monterrey had a $2.9 million city contract rescinded following an ethics violation finding, and was investigated by the FBI in connection with a no-bid Rosemont contract.
Campaign contributions
Illinois State Board of Elections records show Juan Gaytan and Monterrey Security made combined contributions totaling $306,621 across 255 transactions to Illinois political committees. George Cardenas, who chairs the City Council Transportation Committee - the committee with oversight jurisdiction over the CTA - received $3,500 from Gaytan in 2025 while the Monterrey contract was active. Mayor Brandon Johnson received $3,000 from Gaytan in July 2023. The 25th Ward Regular Democratic Organization received $6,000.
The most recent contribution in the records: $1,750 to the Rosemont Voters League, dated March 13, 2026 - five weeks before the CTA terminated the Monterrey contract.
The Termination
A contract cancelled three weeks after it was renewed
On April 18, 2026, the CTA terminated the Monterrey contract. The termination came approximately three weeks after the contract had been renewed for a one-year term through April 3, 2027. The CTA cited non-appropriation of funds - a budget-based termination clause - despite having just executed an affirmative renewal. Contract renewals are not automatic. Someone at the CTA signed the renewal.
The buyer of record on both the original Monterrey contracts and the Inter-Con contract was Iliana Linares, listed in CTA procurement records as General Manager of Purchasing. That role includes processing contract renewals. The sequence - renewal executed, then termination invoked three weeks later, citing lack of appropriated funds - is, at minimum, a procurement anomaly that warrants explanation.
Two NLRB unfair labor practice cases involving Monterrey Security and SEIU Local 1 were filed in March 2025 and dismissed in April 2025. Dismissal letters are pending production under FOIA 2026-NLFO-01071. The NLRB categorized PolicyTorque as a media organization and waived all fees.
The Investigation
What has been filed and what is pending
Fourteen FOIA requests have been filed across federal, state, and municipal agencies. The DOAH dataset has been produced and analyzed. Contract records were obtained through the city's public procurement portal. CTA board ordinances 022-034 and 024-140 were obtained and reviewed. Illinois State Board of Elections contribution data was analyzed. A complaint was filed with the Illinois Attorney General's Public Access Counselor regarding CPD's refusal to produce citation and arrest data in a form that identifies what the undefined "Other" arrest category contains.
This investigation is active. Records are still arriving. What is already in hand is sufficient to describe the core finding: a public transit authority spent $251 million on private security while generating $26,148.57 in fare enforcement fines, contracted with a company whose founder resigned from CPD under suspension and whose co-founder is related to a convicted corrupt alderman, allowed that company's contracts to exceed board authorization by $26 million before seeking retroactive approval, and then terminated a contract three weeks after renewing it.
The questions that remain are how the overspend was authorized at the operational level, what the Change Order No. 1 actually did, and why the contract renewal and termination happened in the sequence they did. Those questions are pending production.
Michael Russo is the founder of PolicyTorque LLC. He is an independent policy researcher and journalist. He has no financial interest in any entity named in this article. Primary source documents supporting this analysis are available upon request. Contact: michael@policytorque.com