delivered the opinion of the court:
The City of Chicago appeals a judgment of the appellate court reversing the circuit court of Cook County’s dismissal of count II of plaintiff Gail P. Harinek’s second-amended complaint. In addition, plaintiff seeks cross-relief reversing the appellate court’s affirmance of the trial court’s dismissal of count III of the complaint. The appellate court concluded that count II was sufficient to allow plaintiff to maintain an action against the City for alleged negligence in planning and conducting a fire drill, but that count III failed adequately to allege that the City’s conduct was willful and wanton. For the reasons that follow, we hold that the complaint is insufficient to support either of these claims.
BACKGROUND
Count I of the complaint alleged that defendant 161 North Clark Street Ltd. Partnership (the Partnership) owned and operated an office building in which plaintiff worked. Count I further alleged that the Partnership negligently allowed a heavy door with no window to be constructed near an elevator corridor and failed to provide adequate warnings as to the dangerous condition of the door. The count alleged that as a result of this conduct, plaintiff was hit and injured by the door during a fire drill.
Count II alleged that the City of Chicago’s fire marshal personally planned and conducted a fire drill in the building on April 28, 1993. Count II further alleged that, during the fire drill, the marshal negligently directed a large group of people, including plaintiff, to stand in the vicinity of the door, and that as a result, plaintiff was hit and injured by the door when someone opened it without warning. The count also alleged that the marshall was negligent in failing to inspect the door to ascertain whether it was safe, failing to warn those passing through and standing by the door of its danger, and failing to establish alternate routes not involving the door for use during the fire drill.
Count III repeated the factual allegations of count II, but asserted further that the fire marshal’s conduct was willful and wanton because he was on notice that the area in which he directed the group of people to stand was unsuitable for that purpose.
Both the Partnership and the City moved to dismiss the complaint under section 2 — 615 of the Code of Civil Procedure (735 ILCS 5/2 — 615 (West 1994)). The circuit court denied the Partnership’s motion to dismiss count I, but granted the City’s motion to dismiss counts II and III based on the Local Governmental and Governmental Employees Tort Immunity Act (the Act) (745 ILCS 10/ 2 — 101 (West 1994)). The court also found that there was no just cause to delay enforcement or appeal of its order dismissing counts II and III (see 134 Ill. 2d R. 304(a)).
The appellate court reversed the circuit court’s dismissal of count II, ruling that the Act does not immunize the City from liability for the fire marshal’s conduct as described in the complaint. 283 Ill. App. 3d 491. The court first held that sections 5 — 102 and 5 — 103(b) of the Act (745 ILCS 10/5 — 102, 5 — 103(b) (West 1994)) are inapplicable because these sections pertain only to firefighters’ performance in fighting a fire or to the City’s failure to provide adequate personnel, equipment, or facilities for fire protection.1 283 Ill. App. 3d at 494-95. The court also held that section 2 — 201 of the Act (745 ILCS 10/2 — 201 (West 1994)) does not preclude liability because the fire marshal’s conduct in “directing plaintiff to stand behind a door, though discretionary, is not a policy determination within the meaning of the Act.” 283 Ill. App. 3d at 496. The court affirmed, however, the trial court’s dismissal of count III, holding that plaintiffs injury was not the result of willful and wanton conduct on the part of the fire marshal. 283 Ill. App. 3d at 497. This court allowed the City’s petition for leave to appeal (166 Ill. 2d R. 315(a)).
ANALYSIS
Discretionary Acts
The City contends that permitting it to be held liable for the injuries plaintiff sustained during the fire drill would violate sections 2 — 109 and 2 — 201 of the Tort Immunity Act (745 ILCS 10/2 — 109, 2 — 201 (West 1994)). These sections provide as follows:
“A local public entity is not liable for an injury resulting from an act or omission of its employee where the employee is not liable.” 745 ILCS 10/2 — 109 (West 1994).
“Except as otherwise provided by Statute, a public employee serving in a position involving the determination of policy or the exercise of discretion is not liable for an injury resulting from his act or omission in determining policy when acting in the exercise of such discretion even though abused.” 745 ILCS 10/2 — 201 (West 1994).
The Illinois Constitution of 1970 abolished sovereign immunity in Illinois, except as the General Assembly may provide by law. Ill. Const. 1970, art. XIII, § 4. Consequently, the Tort Immunity Act governs whether and in what situations local governmental units are immune from civil liability. Epstein v. Chicago Board of Education, 178 Ill. 2d 370, 375 (1997). In construing the Act, our primary goal is to ascertain and give effect to the intention of the legislature. Barnett v. Zion Park District, 171 Ill. 2d 378, 388 (1996). We will not depart from the plain language of the Act by reading into it exceptions, limitations, or conditions that conflict with the express legislative intent. Barnett, 171 Ill. 2d at 389.
The City argues that sections 2 — 109 and 2 — 201 of the Act immunize a local public entity from liability if its act or omission which allegedly caused a plaintiff’s injury constituted an exercise of discretion. The City asserts that the appellate court erred in requiring that the act or omission also had been a policy determination. The City contends that, prior to the instant case, no court had construed section 2 — 201 as requiring that a public entity’s act or omission had been both an exercise of discretion and a policy determination. The City also argues that even if the statute is construed to require that the act or omission had been a policy determination, the fire marshal’s conduct as described in the complaint satisfies this requirement.
Plaintiff responds that the clear language of the statute provides immunity only when the public entity’s act or omission was both an exercise of discretion and a policy determination. Plaintiff argues that these two characteristics of a public entity’s conduct are separate and distinct, and must both be satisfied independently for immunity to attach. Plaintiff contends further that the appellate court correctly determined that the fire marshal’s conduct in this case did not constitute a policy determination, but asserts that the court erred in holding that the marshal’s conduct was discretionary.
This court has not previously addressed the issue of whether section 2 — 201 requires that a public entity’s act or omission be both an exercise of discretion and a policy determination. By its plain language, the statute immunizes a public employee who serves in “a position involving the determination of policy or the exercise of discretion” from liability for injuries allegedly caused by the employee’s “act or omission in determining policy when acting in the exercise of such discretion.” 745 ILCS 10/2 — 201 (West 1994). This language makes clear that the statute is concerned with both the type of position held by the employee and the type of action performed or omitted by the employee.
According to the statute, an employee may be granted immunity if he holds either a position involving the determination of policy or a position involving the exercise of discretion. The statute is equally clear, however, that immunity will not attach unless the plaintiffs injury results from an act performed or omitted by the employee in determining policy and in exercising discretion. The employee’s position thus may be one which involves either determining policy or exercising discretion, but, as the appellate court correctly held, the act or omission must be both a determination of policy and an exercise of discretion.
In the instant case, plaintiff apparently concedes that the fire marshal’s position involves either the determination of policy or the exercise of discretion. Plaintiff contends, however, that the appellate court correctly determined that the acts and omissions of the marshal described in the complaint were not determinations of policy. We disagree. The appellate court held that the fire marshal’s act of “directing plaintiff to stand behind a door, though discretionary, is not a policy determination within the meaning of the Act.” 283 Ill. App. 3d at 496. In so holding, the appellate court mischaracterized the nature of the conduct described in the complaint.
The complaint alleges that the City of Chicago fire department “planned, controlled, operated, and implemented” a fire drill at plaintiff’s place of employment on the date she was injured. The complaint further alleges that the fire marshal assembled plaintiff and her fellow employees in a corridor near the door which struck plaintiff, but that the marshal failed to place any warnings on the door and failed to provide adequate alternate routes for use during the fire drill. The complaint also alleges that the assembling of plaintiff and her fellow employees in the corridor in the vicinity of the door was carried out pursuant to a plan developed by the marshal before the fire drill began.
We hold that these allegations describe acts and omissions of the fire marshal in determining fire department policy. This court has previously defined “policy decisions made by a municipality” as “those decisions which require the municipality to balance competing interests and to make a judgment call as to what solution will best serve each of those interests.” West v. Kirkham, 147 Ill. 2d 1, 11 (1992). The conduct described in the instant complaint falls squarely within this definition. The fire marshal is responsible for planning and conducting fire drills in the City of Chicago. In planning these drills, the marshall must balance various interests which may compete for the time and resources of the department, including the interests of efficiency and safety. The alleged acts and omissions outlined in the complaint, such as the marshal’s decisions regarding where to assemble the participants and whether to provide warning signs and alternate routing, were all part of his attempts to balance these interests. Accordingly, these acts and omissions were undertaken in determining policy within the meaning of the statute.
Plaintiff contends in the alternative that the appellate court erred in holding that the fire marshal’s conduct was discretionary. In construing section 2 — 201 of the Act, this court has held that
“discretionary acts are those which are unique to a particular public office, while ministerial acts are those which a person performs on a given state of facts in a prescribed manner, in obedience to the mandate of legal authority, and without reference to the official’s discretion as to the propriety of the act.” Snyder v. Curran Township, 167 Ill. 2d 466, 474 (1995).
Under these standards, the fire marshal’s conduct described in the complaint clearly constituted an exercise of discretion. The marshal bears sole and final responsibility for planning and executing fire drills in buildings throughout Chicago. He is under no legal mandate to perform these duties in a prescribed manner; rather, he exercises his discretion in determining how, when, and where to hold drills such as the one in which plaintiff was injured. The appellate court was therefore correct in concluding that the fire marshal’s conduct was discretionary.
Because the fire marshal occupied a position involving the determination of policy or the exercise of discretion, and because his conduct as described in the complaint constituted acts or omissions in determining policy and exercising discretion, section 2 — 201 of the Act immunizes the City from liability for plaintiff’s injuries.
The “Special Duty” Doctrine
Plaintiff contends that even if the fire marshal’s conduct is immunized by section 2 — 201 of the Act, the City may nevertheless be held liable because the marshal owed plaintiff a “special duty” to protect her from the injuries which she suffered. The City responds that when a public entity is found to be immunized from liability by the Act, courts are not authorized to make exceptions to the Act which would nevertheless permit the imposition of liability.
Under the doctrine of sovereign immunity, a governmental unit in Illinois was immune from tort liability. Barnett v. Zion Park District, 171 Ill. 2d 378, 385 (1996). In 1959, however, this court abolished the sovereign immunity of municipal corporations in tort actions. Molitor v. Kaneland Community Unit District No. 302, 18 Ill. 2d 11 (1959); see also Walker v. Forest Preserve District, 27 Ill. 2d 538, 540 (1963) (holding that in Molitor “the sovereign immunity of municipal corporations in tort actions was abolished”). In response to Molitor, the General Assembly in 1965 enacted the Local Governmental and Governmental Employees Tort Immunity Act (745 ILCS 10/1 — 101 et seq. (West 1994)). The Act adopted the general principle from Molitor that local governmental units are liable in tort, but limited this liability with an extensive list of immunities based on specific government functions. Burdinie v. Village of Glendale Heights, 139 Ill. 2d 501, 506 (1990).
The ratification of the Illinois Constitution of 1970 validated both Molitor and the Tort Immunity Act. Article XIII, section 4, of the Illinois Constitution reads as follows: “Except as the General Assembly may provide by law, sovereign immunity in this State is abolished.” Ill. Const. 1970, art. XIII, § 4. This provision embodies the presumptive rule from Molitor that units of local government are subject to tort liability, but “makes the General Assembly the ultimate authority” in determining whether such a unit is nevertheless immune from liability. Burdinie, 139 Ill. 2d at 510. Therefore, governmental units are now liable in tort on the same basis as private tortfeasors unless a valid statute dealing with tort immunity imposes conditions upon that liability. Barnett, 171 Ill. 2d at 386. Where such statutory conditions are found to exist, tort liability is precluded.
The “special duty” doctrine which plaintiff seeks to apply in the instant case originated as an exception to the common law “public duty” rule. According to the public duty rule, a municipality could not be held liable for its failure to provide adequate governmental services, such as police and fire protection. Huey v. Town of Cicero, 41 Ill. 2d 361, 363 (1968). The rationale for this rule was that the duty of a municipality to provide governmental services was owed to the public at large and therefore took precedence over any duty owed to a particular plaintiff. See Calloway v. Kinkelaar, 168 Ill. 2d 312, 334 (1995) (Freeman, J., specially concurring); Leone v. City of Chicago, 156 Ill. 2d 33, 47 (1993) (Bilandic, J., dissenting); Gebhardt v. Village of LaGrange Park, 354 Ill. 234, 237-38 (1933).
Despite abolishing common law sovereign immunity in Molitor, this court has nevertheless retained the public duty rule. As the court explained in Huey, the public duty rule exists “[independent of *** common-law concepts of sovereign immunity.” Huey, 41 Ill. 2d at 363. Therefore, although, absent a statutory immunity, governmental units are now liable in tort on the same basis as private tortfeasors, the public duty rule nevertheless prevents such units from being held liable for their failure to provide adequate governmental services.
In 1966, the appellate court first recognized an exception to the public duty rule now known as the “special duty” doctrine. In Gardner v. Village of Chicago Ridge, 71 Ill. App. 2d 373 (1966), the court held that, notwithstanding the public duty rule, police officers employed by a municipality could be held liable for their failure to protect a plaintiff from injury by others if the facts of the case showed that the officers undertook to exercise a particular duty of care or custody over the plaintiff. Gardner, 71 Ill. App. 2d at 378. Subsequently, in 1968, this court acknowledged that an exception to the public duty rule exists where “the municipality was under a special duty to a particular individual.” Huey, 41 Ill. 2d at 363.
Plaintiff in the instant case urges us to apply the special duty doctrine to override the immunity granted the City by the Tort Immunity Act. As this court emphasized in Huey, however, the basis for the public duty rule is “[independent of statutory *** concepts of sovereign immunity.” Huey, 41 Ill. 2d at 363. As we have more recently explained, “the existence of a duty and the existence of an immunity are separate issues.” Barnett, 171 Ill. 2d at 388. Therefore, the question of whether the City owed plaintiff a duty under the special duty doctrine has no bearing on the separate question of whether the Act immunizes the City from liability for plaintiff’s injuries.
As noted previously, article XIII, section 4, of the Illinois Constitution “makes the General Assembly the ultimate authority in determining whether a unit of local government is immune from tort liability.” Burdinie, 139 Ill. 2d at 510. Thus, when a court finds, on the facts of a particular case, that the General Assembly has granted a public entity immunity from liability, the court may not then negate that statutory immunity by applying a common law exception to a common law rule. Doing so would violate not only the Illinois Constitution’s provision governing sovereign immunity (Ill. Const. 1970, art. XIII, § 4), but also the Constitution’s separation of powers clause, which provides that no branch of government “shall exercise powers properly belonging to another.” Ill. Const. 1970, art. II, § 1. The special duty doctrine simply allows courts to impose liability upon a municipality by making an exception to the public duty rule in cases in which the legislature has not granted immunity to the municipality. Thus, the special duty doctrine may not operate to impose liability upon a public entity after a court has found that entity immune from liability under the Tort Immunity Act. Previous holdings to the contrary by this court and the appellate court are hereby overruled.
In the instant case, because we find that the Act immunizes the City from liability for plaintiffs injuries, the question of whether the fire marshal had a special duty to plaintiff is irrelevant.
Willful and Wanton Conduct
Plaintiff also seeks cross-relief reversing the appellate court’s holding that the fire marshal’s alleged conduct was not willful and wanton. Even willful and wanton conduct, however, cannot deprive a municipality of an immunity granted by section 2 — 201 of the Act (745 ILCS 10/2 — 201 (West 1994)). In re Chicago Flood Litigation, 176 Ill. 2d 179, 196 (1997). Because we find that the City is immune from liability under section 2 — 201, it is unnecessary for us to consider whether the fire marshal’s alleged conduct was willful and wanton.
CONCLUSION
For the reasons stated, we reverse the appellate court’s holding that count II of the complaint was sufficient to state a cause of action against the City, and affirm the circuit court’s dismissal of that count. We also affirm the judgments of the appellate and circuit courts dismissing count III of the complaint.
Appellate court judgment affirmed in part and reversed in part; circuit court judgment affirmed.
The City has not addressed sections 5 — 102 and 5 — 103(b) in its current arguments before this court.