JUSTICE STEIGMANN delivered the opinion of the court:

On May 19, 2004, the trial court ordered that a taxdeed be issued to petitioner, Laurence D. Craig, for real property located at 512 N. Madison Street in Lincoln. The next day,respondent, Linda Brown, who resided at the subject property,filed a motion to vacate the tax deed. Following a June 2004hearing, the court denied Brown's motion.

In July 2004, Brown filed motions to (1) vacate the taxdeed under section 2-1401 of the Code of Civil Procedure (CivilCode) (735 ILCS 5/2-1401 (West 2002)) and (2) declare section 22-45 of the Property Tax Code (35 ILCS 200/22-45 (West 2002))unconstitutional under the equal-protection clause of the UnitedStates Constitution (U.S. Const., amend. XIV). Following a July2004 hearing, the trial court denied both motions and orderedBrown to vacate and surrender the subject property.

Brown appeals, arguing that the trial court erred by(1) denying her motion to vacate the tax deed under section 2-1401 of the Civil Code and (2) denying her motion to declaresection 22-45 of the Property Tax Code unconstitutional. Weaffirm.

In October 2001, Craig purchased the unpaid taxes onthe subject property at an annual auction sale of real estate fornonpayment of general taxes. In January 2004, Craig filed apetition for a tax deed, and a take notice was mailed to interested parties and published in The Courier, a local newspaper. Pursuant to the take notice, the period in which an interestedparty could redeem the property expired on April 29, 2004. A May3, 2004, docket entry states that as of that date, no objectionor pleading had been filed. On May 19, 2004, the trial courtentered an order directing the Logan County clerk to issue a taxdeed conveying the property to Craig.

On May 20, 2004, Brown filed a motion to vacate the taxdeed, alleging as follows: (1) she was entitled to title to theproperty at issue, and litigation to quiet title was pending inLogan County case No. 00-LM-07; (2) after being served with thenotice of the proceeding for the tax deed, she contacted theLogan County clerk and recorder's office and was told that shewould not be able to redeem the property; (3) based on thatinformation, she did not file a pleading in the case; (4) sheattempted to attend the hearing on the petition for the tax deedbut was unable to locate the hearing and was told by the LoganCounty clerk's office that it had no record of the hearing; (5)when the Logan County clerk discovered record of the hearing, thehearing had already concluded; and (6) if the trial court hadknown of her claim to the property, the court would not havegranted Craig's petition for the tax deed.

On June 15, 2004, Craig filed a motion entitled "Motionto Dismiss Or In [the] Alternative For Summary Judgment." Inthat motion, Craig argued that (1) Brown lacked standing tochallenge the tax deed because (a) Brown did not attach any proofof title or ownership to her motion to vacate the tax deed, (b)no filing with the recorder's office showed that Brown had aninterest in the property, and (c) Brown's counterclaim in LoganCounty case No. 00-LM-07 did not constitute ownership or give hera right to redeem the property; and (2) Brown's motion to vacatethe tax deed was insufficient on its face because it failed tomeet the requirements of section 22-45 of the Property Tax Code(35 ILCS 200/22-45 (West 2002)).

On June 18, 2004, the trial court conducted a hearingon Brown's motion to vacate the tax deed and took the matterunder advisement. On June 25, 2004, the court entered thefollowing docket entry:

"Court finds that under 35 ILCS 200/22-45 ***tax deeds are not contestable except by direct appeal or under 735 ILCS 5/2-1401. This[c]ourt does hereby deny [Brown's] [m]otion[t]o [v]acate [t]ax [d]eed. Mr. [Douglas A.]Muck and Mr. [Thomas W.] Funk [(counsel forCraig and Brown, respectively)] notified byletter."

Also on June 25, 2004, the court mailed identical letters to Muckand Funk. (Both letters were file-stamped by the Logan Countyclerk on June 25, 2004.) The body of the letter consisted of oneparagraph, quoted below in its entirety:

"I am writing to you in regards to myruling in the above captioned case. Afterreviewing the cases cited[,] the [c]ourtfinds that under 35 ILCS 200/22-45 that taxdeeds are not contestable except by directappeal or under 735 ILCS 5/2-1401. This[c]ourt does hereby deny [Brown's] [m]otionto [v]acate [t]ax [d]eed."

On July 9, 2004, Brown filed a motion to vacate the taxdeed under section 2-1401 of the Civil Code (735 ILCS 5/2-1401(West 2002)). In that petition, Brown alleged, in pertinentpart, that (1) she owned the subject property; (2) she was livingthere on the date the redemption period expired; and (3) becauseof her reliance on the erroneous advice of a Logan County employee, she had missed the opportunity to redeem the property.

On July 12, 2004, Brown filed a motion to declaresection 22-45 of the Property Tax Code (35 ILCS 200/22-45 (West2002)) unconstitutional under the equal-protection clause of theUnited States Constitution (U.S. Const., amend. XIV). Specifically, she claimed that (1) section 22-45 of the Property TaxCode affords residents of counties with a population over 3million an additional way to seek relief after a tax deed isissued and (2) but for the fact that the subject property waslocated in a county with a population below 3 million, she wouldhave been entitled to relief under section 22-45. Also on thatdate, Brown filed a motion to stay enforcement of the trialcourt's judgment pending hearing and appeal.

Also on July 12, 2004, the trial court conducted ahearing on Brown's motions to declare section 22-45 unconstitutional and stay enforcement of its judgment. At the start ofthat hearing, Muck presented the court with a written order hehad prepared based on the court's June 25, 2004, letter ruling. The court agreed that an order needed to be entered, and Muck andFunk agreed to make some modifications to the prepared order andresubmit it to the court.

On July 16, 2004, the trial court entered a writtenorder that (1) denied Brown's May 20, 2004, motion to vacate thetax deed and (2) granted Craig's motion to dismiss, or alternatively, for summary judgment.

Following a July 19, 2004, hearing on Brown's (1) July9, 2004, motion to vacate the tax deed under section 2-1401 ofthe Civil Code (735 ILCS 5/2-1401 (West 2002)) and (2) July 12,2004, motion to declare section 22-45 of the Property Tax Code(35 ILCS 200/22-45 (West 2002)) unconstitutional, the trial courtdenied both motions. On August 13, 2004, the court entered awritten order, denying both of Brown's motions and ordering herto vacate and surrender the subject property.

Also on August 13, 2004, Brown filed a notice ofappeal.

Craig argues that this court lacks jurisdiction toconsider Brown's appeal of the trial court's May 19, 2004, orderbecause her August 13, 2004, notice of appeal was not timelyfiled. Specifically, he contends that (1) the trial court deniedBrown's May 20, 2004, motion to vacate the tax deed on June 25,2004, and (2) Brown's subsequent motions were improper successiveposttrial motions that did not toll the Supreme Court Rule303(a)(1) requirement that a notice of appeal must be filedwithin 30 days of the court's ruling on a posttrial motion (155Ill. 2d R. 303(a)(1)). Brown responds that her August 13, 2004,notice of appeal was timely because (1) the trial court did notrule on her May 20, 2004, motion to vacate the tax deed untilJuly 16, 2004; or, in the alternative, (2) she is appealing thetrial court's August 13, 2004, order denying her section 2-1401motion and her motion to declare section 22-45 of the PropertyTax Code unconstitutional. We agree with Craig that we lackjurisdiction to consider Brown's appeal of the court's May 19,2004, order. However, we have jurisdiction to consider thecourt's August 2004 order denying Brown's section 2-1401 motionand motion to declare section 22-45 unconstitutional.

1. Jurisdiction To Review the Trial Court's May 19, 2004, Order

Brown contends that her August 13, 2004, notice ofappeal was timely because the trial court did not rule on her May20, 2004, motion to vacate the tax deed until July 16, 2004, whenthe court signed the written order prepared by Muck. However,whether Brown's notice of appeal was timely filed turns initiallyon whether the court's June 25, 2004, order denying her motion tovacate the tax deed constituted an "order disposing of the lastpending post[]judgment motion" under Supreme Court Rule 303(a)(1)(155 Ill. 2d R. 303(a)(1)). If so, the 30-day clock beganticking on that date, and Brown's August 13, 2004, notice ofappeal was untimely.

In our view, the analysis used to determined when anorder is final for purposes of appeal should also apply to ordersdisposing of posttrial motions that start the clock under Rule303. "A final order or judgment is a determination by the courton the issues presented by the pleadings which ascertains andfixes absolutely and finally the rights of the parties to thelitigation." Physicians Insurance Exchange v. Jennings, 316 Ill.App. 3d 443, 450, 736 N.E.2d 179, 185 (2000). Supreme Court Rule272 explains precisely when a judgment becomes "final" as follows:

"If at the time of announcing finaljudgment the judge requires the submission ofa form of written judgment to be signed bythe judge or if a circuit court rule requiresthe prevailing party to submit a draft order,the clerk shall make a notation to that effect and the judgment becomes final only whenthe signed judgment is filed. If no suchsigned written judgment is to be filed, thejudge or clerk shall forthwith make a notation of judgment and enter the judgment ofrecord promptly, and the judgment is enteredat the time it is entered of record." 137Ill. 2d R. 272.

In both the trial court's docket entry and its letterto Muck and Funk, the court stated that it "hereby denied"Brown's motion to vacate the tax deed. Neither the docket entrynor the letter indicated that the court required the submissionof a form of written judgment. The plain language of Rule 272provides that in the absence of such an indication made "at thetime of announcing final judgment," an order becomes final at thetime it is entered of record. We thus conclude that the court'sorder denying Brown's motion to vacate the tax deed took effecton June 25, 2004, when the order was entered of record. Accordingly, Brown's August 13, 2004, notice of appeal was not timelyfiled, and we lack jurisdiction over her appeal of the court'sMay 19, 2004, order.

By so concluding, we necessarily answer in the negativethe following question: Does subsequent action by the trialcourt (whether sua sponte or upon request) indicating that awritten judgment is to be signed render a previously enterednotation judgment no longer of effect? As the First Districtwrote in Martin v. Cajda, 238 Ill. App. 3d 721, 728, 606 N.E.2d566, 571 (1992):

"The notions of the court and the parties as to the finality of an order will notrender a final order nonfinal. [Citations.] Nor will a trial court's misapprehension ofthe law allow an appellant to file his noticeof appeal more than 30 days after the trialcourt issues what actually constitutes afinal order."

Moreover, the language of Rule 272 is as strong as it could beand is unique within supreme court rules. To accept the argumentthat the trial court's later written order restarted the clockfor calculating the time in which to appeal would be to read outthe first clause of Rule 272, where it states: "If at the timeof announcing final judgment the judge requires the submission ofa form of written judgment ***." (Emphasis added.) 137 Ill. 2dR. 272. When analyzing supreme court rules, we apply the samerules of construction used in the analysis of statutes (Andersonv. Financial Matters, Inc., 285 Ill. App. 3d 123, 135, 672 N.E.2d1261, 1269 (1996)), and when construing a rule or statute, courtsshould not adopt a meaning that renders any clause meaningless orsuperfluous (Follett Corp. v. Department of Revenue, 344 Ill.App. 3d 388, 395, 800 N.E.2d 159, 164 (2003)).

Even though our construction of Rule 272 is consistentwith the rule's clear language, we can understand why someuncertainty existed on the part of the trial court and counselbecause this decision appears to be the first to explain, inbright-line terms, the effect of the rule's first clause.

2. Jurisdiction To Review the Trial Court's Order Denying Brown's Section 2-1401
Motion and Motion To Declare Section 22-45 of the Property Tax Code Unconstitutional

Craig contends that this court lacks jurisdiction overBrown's appeal of the trial court's August 13, 2004, order because after Brown filed her August 13, 2004, notice of appeal,he filed a timely posttrial motion (August 20, 2004) that invalidated Brown's August 13, 2004, notice of appeal. Brown respondsthat Craig's August 20, 2004, motion was not a motion against thejudgment. We agree with Brown.

Only a motion "directed against the judgment" underSupreme Court Rule 303(a)(1) (155 Ill. 2d R. 303(a)(1)) orspecified in section 2-1203 of the Civil Code (735 ILCS 5/2-1203(West 2002)) qualifies as a postjudgment motion that renders aprior notice of appeal of no effect. See R&G, Inc. v. MidwestRegion Foundation for Fair Contracting, Inc., 351 Ill. App. 3d318, 325, 812 N.E.2d 1044, 1049 (2004). That section allows fora party to file a motion "for a rehearing, or a retrial, ormodification of the judgment or to vacate the judgment or forother relief." 735 ILCS 5/2-1203(a) (West 2002).

Craig's August 20, 2004, motion to reconsider asked thecourt to reconsider and strike two factual findings included inthe court's August 13, 2004, order--namely, that (1) the "verified motion to vacate the tax deed establishes [Brown's] equitable ownership of the subject premises" and (2) "[Brown] attemptedto redeem the property but was prevented from doing so." Craig'sAugust 20, 2004, motion did not challenge the trial court'sjudgment and thus did not render Brown's August 13, 2004, noticeof appeal of no effect. Accordingly, we conclude that Brown'sappeal of the trial court's August 13, 2004, order denying hersection 2-1401 motion and motion to declare section 22-45 unconstitutional was timely filed, and we have jurisdiction to reviewthem.

Brown next argues that the trial court erred by denyingher motion to vacate the tax deed under section 2-1401 of theCivil Code (735 ILCS 5/2-1401 (West 2002)). We disagree.

Section 2-1401(a) of the Civil Code provides for"[r]elief from final orders and judgments, after 30 days from theentry thereof." 735 ILCS 5/2-1401(a) (West 2002). Under section22-45 of the Property Tax Code, grounds for relief under section2-1401 are limited to the following:

"(1) proof that the taxes were paidprior to sale;

(2) proof that the property was exemptfrom taxation;

(3) proof by clear and convincing evidence that the tax deed had been procured byfraud or deception by the tax purchaser orhis or her assignee; or

(4) proof by a person or party holding arecorded ownership or other recorded interestin the property that he or she was not namedas a party in the publication notice as setforth in [s]ection 22-20, and that the taxpurchaser or his or her assignee did not makea diligent inquiry and effort to serve thatperson or party with the notices required by[s]ections 22-10 through 22-30." 35 ILCS200/22-45 (West 2002).

Brown's section 2-1401 motion to vacate the tax deed did notallege any of the enumerated grounds for relief in section 22-45of the Property Tax Code. We thus conclude that the trial courtdid not err by denying Brown's section 2-1401 motion to vacatethe tax deed.

Last, Brown argues that the trial court erred bydenying her motion to declare section 22-45 of the Property TaxCode unconstitutional under the equal-protection clause of theUnited States Constitution (U.S. Const., amend XIV). Specifically, she contends that (1) the final paragraph of section 22-45would entitle her to relief but for the fact that the subjectproperty is not located in a county with 3 million or moreinhabitants and (2) this population-based classification isarbitrary. We disagree.

The provision of section 22-45 that Brown claims isunconstitutional provides as follows:

"In cases of the sale of homestead property in counties with 3,000,000 or more inhabitants, a tax deed may also be voided bythe court upon petition, filed not more than[three] months after an order for tax deedwas entered, if the court finds that theproperty was owner occupied on the expirationdate of the period of redemption and that theorder for deed was effectuated pursuant to anegligent or willful error made by an employee of the county clerk or county collector during the period of redemption from thesale that was reasonably relied upon to thedetriment of any person having a redeemableinterest." 35 ILCS 200/22-45 (West 2002).

We review de novo a challenge to the constitutionalityof a statute. Statutes carry a strong presumption of constitutionality, and the party challenging the statute has the burdenof rebutting that presumption. This court has a duty to upholdthe constitutionality of a statute if it is reasonably possibleto do so. Village of Lake Villa v. Stokovich, 211 Ill. 2d 106,121-22, 810 N.E.2d 13, 23 (2004).

The legislature may, in the enactment of general laws,classify counties and municipalities on the basis of populationso long as the classification is not arbitrary or does not granta particular class special or exclusive legislative favors. Inre Belmont Fire Protection District, 111 Ill. 2d 373, 379-80, 489N.E.2d 1385, 1388 (1986). We presume that legislative classifications are constitutionally valid and resolve any reasonabledoubt in favor of upholding the classification. Village ofChatham v. County of Sangamon, 351 Ill. App. 3d 889, 899, 814N.E.2d 216, 226 (2004). "A reviewing court will also presume thelegislature acted conscientiously and considered the conditionsprevailing in the counties before enacting the legislation." Village of Chatham, 351 Ill. App. 3d at 899, 814 N.E.2d at 226. To withstand constitutional scrutiny, a population-based classification "'must be based upon a rational difference of situationor condition found to exist in the persons or objects upon whichthe classification rests.'" Village of Chatham, 351 Ill. App. 3dat 899, 814 N.E.2d at 225, quoting Belmont Fire ProtectionDistrict, 111 Ill. 2d at 380, 489 N.E.2d at 1388. The classification must bear a rational relationship to the evil to beremedied and the purpose of the legislation. Village of Chatham,351 Ill. App. 3d at 899, 814 N.E.2d at 225.

"If any set of facts can be reasonably conceived that justifies distinguishing theclass to which the statute applies from theclass to which the statute is inapplicable,then the General Assembly may constitutionally classify persons and objects for thepurpose of legislative regulation or control,and may enact laws applicable only to thosepersons or objects." In re Petition of theVillage of Vernon Hills, 168 Ill. 2d 117,122, 658 N.E.2d 365, 367 (1995).

In effect, the disputed provision of section 22-45 ofthe Property Tax Code provides a remedy for residents of CookCounty that it does not provide to residents of any other Illinois county. Cook County's treasurer oversees the second largestproperty tax collection and distribution system in the UnitedStates and collects $8 billion each year in taxes from the ownersof more than 1.6 million parcels of property. Seehttp://www.cookcountytreasurer.com (visited February 11, 2005)(Cook County treasurer website); see Ashley v. Pierson, 339 Ill.App. 3d 733, 739-40, 791 N.E.2d 666, 671-72 (2003) (records fromthe Department of Corrections office are public records of whichthe appellate court may take judicial notice). Thus, in CookCounty, a person challenging the issuance of a tax deed must dealwith a vast bureaucracy, unlike in any other county in the state. Given the high volume of tax deeds processed in Cook County andthe number of employees working for the Cook County treasurer,the legislature reasonably could have determined that the likelihood of an error occurring somewhere in the process was greaterthan in a smaller county. The legislature thus reasonably couldhave deemed it necessary to provide an additional avenue forseeking relief, including an extended deadline, when a tax deedwas "effectuated pursuant to a negligent or willful error made byan employee of the county clerk or county collector." 35 ILCS222/22-45 (West 2002). Accordingly, we conclude that thepopulation-based classification in section 22-45 is not arbitraryand does not violate constitutional equal-protection principles.

For the reasons stated, we affirm the trial court'sjudgment.

Affirmed.

APPLETON, J., concurs.

TURNER, J., specially concurs.

JUSTICE TURNER, specially concurring:

I concur in the majority opinion, and I write separately only to address the majority's analysis regarding our lackof jurisdiction to consider respondent's appeal of the trialcourt's May 19, 2004, docket entry order. Although I agree withthe majority that we are required to strictly apply Rule 272 (seeIn re Marriage of Nettleton, 348 Ill. App. 3d 961, 966, 811N.E.2d 260, 265 (2004) (the supreme court demands strict compliance with its rules governing appeal, and neither a trial courtnor an appellate court has the authority to excuse compliancewith the filing requirements of the rules)), I am impelled tovoice my concern with the rule's strict application to the factsin this case.

Here, petitioner's counsel requested the trial court toenter a written order in substitution of the court's prior docketentry. The court agreed to do so and stated:

"We do need to enter an order. *** We do need an order on this forappealing *** [and] it shouldn'ttake too long *** and then therewould be an appeal mode, but we doneed the order."

In my view, it is entirely understandable that respondent'scounsel would have believed the 30-day period in which to appealdid not start to run until entry of the written order. Thus,while we are constrained to follow rules adopted by the supremecourt, relaxation of Rule 272 under these facts appears appropriate. Accordingly, it would be in the interests of justice forthe supreme court to consider respondent's argument if an appealis taken or for the court to offer an appropriate amendment toRule 272 to account for a situation where, as here, even the mostwary practitioner would be beguiled.