ࡱ>  bjbjqq peeV83 L y!!(;!;!;!K$K$K$[y]y]y]y]y]y]yd{~]yK$ $ $@K$K$]y;!;!ry)))K$D;!;![y)K$[y))ov;!G&srPGyy0yr'vvhK$K$)K$K$K$K$K$]y]yS(K$K$K$yK$K$K$K$K$K$K$K$K$K$K$K$K$ : LawLawPalooza 2014 American Planning Association Illinois State Conference David S. Silverman, AICP, Ancel Glink Gregory W. Jones, AICP, Ancel Glink Illinois Land Use Case Law (November 2013 present) 1. Gurba v. Cmty. High Sch. Dist. 155, 2014 IL App (2d) 140098, involved a school district that had constructed bleachers without obtaining city zoning approvals. The neighboring property owners sued the school district, which brought the city into the case. The district defended its actions by claiming it was exempt from local zoning. The trial court disagreed, ruling that school districts cannot ignore local zoning regulations. The trial courts ruling was appealed to the Illinois appellate court, which issued an opinion on September 3. The appellate court upheld the trial court's ruling that the school district was required to obtain zoning approvals prior to installing the bleachers. The appellate court rejected the school district's argument that the city was preempted from applying its zoning regulations on school property because the state constitution declares public education to be a matter of statewide concern. The court first noted that the city was a home-rule municipality with the power to enact and enforce zoning ordinances. While a home rule unit cannot enact ordinances that infringe upon public education, the court concluded that land-use regulations have no inherent impact on the substance of public education. Moreover, the court determined that the Illinois School Code expressly authorizes school districts to seek zoning relief for property it holds. That authorization would have no meaning if a school district were exempt from local zoning. 2. In Platform I Shore, LLC v. Vill. of Lincolnwood, 2014 IL App (1st) 133923, the court overturned a municipal decision to deny a permit to allow a firing range on property located in a business district. The owner of the proposed firing range applied for a building permit to construct a shooting range on the second floor of the building above an existing gun shop, relying on the "health clubs and recreation" uses that were permitted by-right in the business district. The village's zoning officer denied the application, stating that a firing range did not fall within the "recreation" use. The owner appealed to the ZBA, which agreed with the zoning officer's interpretation. The owner then appealed to the circuit court, which also upheld the zoning officer's interpretation, holding that the court was required to defer to the villages interpretation of its own ordinance. On appeal, the appellate court reviewed the village's zoning ordinance, and specifically the use list in the business district that expressly allowed "health club or recreation facility, private" as a permitted by-right use. The court reasoned that the plain meaning of recreation includes activities for entertainment and amusement, and the zoning ordinance includes sports as an aspect of recreation. The court also said that common sense dictates that target shooting is also considered a sport as it is an Olympic sporting event and a recognized sporting activity within our national college associations and 4-H clubs. As a result, the court held that the proposed shooting range was permitted in the business district and the permit should have been issued. Interestingly, the village has since amended its zoning ordinance to specifically address shooting ranges and to exclude them from the definition of "recreation." The court did not address the subsequent amendment, instead it applied the zoning ordinance as it existed on the date the owner filed its application for a permit to develop the shooting range. 3. In Cenergy Glenmore Wind Farm No. 1, LLC v. Town of Glenmore, 13-2633, 2014 WL 3867527 (7th Cir. 2014), the Seventh Circuit Court of Appeals dismissed a challenge to the local governmental body's actions regarding an application for permits for a proposed wind farm. The plaintiff sought building permits from the town to build seven wind turbines. The project was highly controversial, and angry citizens attended town board meetings to protest the proposed wind farm project. After months of meetings, the town board approved the building permit applications at a public meeting. However, after citizens threatened the chair and board members, the board voted to rescind its approval at that same meeting. Then, a week later, the town board rescinded its decision to rescind approval. The approvals were never issued, however, because of deficiencies in the applications. Since CEnergy failed to obtain the necessary permits by March 1st, it lost its contract rights to build the wind farm project, and it sued the town claiming that the delay in granting the permits violated its due process rights and vested rights. The district court disagreed, finding that the plaintiff failed to show that its due process rights were violated. The court also held that plaintiff should have sought state law relief to challenge the local land use decision rather than file a federal court action. The Seventh Circuit agreed with the district court, finding that the plaintiff's due process claims failed because the town board's actions were not arbitrary and because CEnergy failed to seek state law relief. The court noted that in order to be "arbitrary," a land use decision must "shock the conscience" or be "egregious official conduct." Here, the town board's decision to delay action on the building permits because of popular opposition to the project was a "rational and legitimate reason for a legislature to delay making a decision." In any event, plaintiff should have brought its land use case to state court, which offers a variety of remedies, including a writ of mandamus. 4. In Chamness v. Mays, 2014 IL App (5th) 130381, appeal pending (Sept. 2014), the court held that a public roadway will not be deemed "abandoned" simply because a public body stops maintaining it for decades, even if the road falls into disrepair. The county and two property owners adjacent to a roadway disputed whether the roadway was a public roadway or had been abandoned by the county. The plaintiff, one of the adjacent property owners argued that the county had abandoned the road when it stopped maintaining it 50 years ago and that title should be vested with plaintiff. The county and the other adjacent property owner disagreed, arguing that the road remained a public roadway even though the county had stopped maintaining the roadway almost 50 years ago. The trial court agreed with the county and defendant owner, holding that abandonment of a public roadway will only be found when the public has waived the right to the road or where the necessity for the road ceases to exist. On appeal, the appellate court agreed with the trial court, finding that an established public road "does not lose its character as a public road unless it is either vacated by the authorities in the manner prescribed by statute or abandoned." In this case, the defendant owner's property was landlocked, and there was no other road that would provide access. There was also no evidence that the county had formally vacated the road. The fact that the county had not maintained the road in decades and the road had fallen into disrepair did not change the fact that the road was necessary for access. 5. In MAUM Meditation House of Truth v. Lake Cnty., No. 13-cv-3794, 2014 WL 3514989 (N.D. Ill. 2014), the district court dismissed MAUM Meditation House of Truths claims that the county violated its First Amendment right to free exercise, its equal protection and due process rights, as well as the Illinois Religious Freedom Restoration Act by failing to deem their conversion of a portion of a home into a meditation center as an accessory use. MAUM argued that a change of use rather than an accessory use would require certain renovations to comply with the code and that those renovations would substantially burden its religious exercise. The county had filed a motion to dismiss the case, arguing that MAUM failed to exhaust its administrative remedies under state law before filing the federal lawsuit. The District Court agreed, and dismissed the case for failure to exhaust administrative remedies and for inadequate pleading. The court also rejected MAUM's argument that the county's application of the building code was a "content-based" regulation, characterizing it as "nonsensical." 6. In Squires Landing, LLC v. City of Rochelle, 2014 IL App (2d) 130818-U, an appellate court required a municipality to refund a $43,000 escrow posted by a developer to secure the construction of public improvements that were required to be constructed under an annexation agreement. In 2005, Squires Landing, LLC entered into a 20 year annexation agreement with the City of Rochelle. As part of the agreement, Squires was required to post a cash escrow in the amount of $43,000 to secure the construction of intersection improvements required for development of the property. The agreement provided that if the $43,000 were not used before the agreement expired, it would be refunded to Squires or its successor. In 2008, the parties agreed that Squires could post a letter of credit in lieu of the cash escrow. The letter of credit provided that if Squires refused or failed to renew the letter of credit, the City could draw on the letter of credit. In 2009, Squires sold the property to AKCK, LLC, and demanded the City release the letter of credit. The City refused to release the letter of credit, and it was renewed until October of 2012. The City then sent a draw to the bank in the full amount of the letter of credit, on the basis that Squires failed to renew the letter of credit in violation of the terms of the annexation agreement. Squires then filed suit, alleging that the City's draw on the letter of credit was improper. The City responded by bringing in the successor property owner, AKCK, alleging that it would be obligated to post an escrow if Squires failed to do so as a successor in interest under the annexation agreement. AKCK responded that Squires did not disclose the escrow requirement when it sold the property to AKCK. The City filed a motion for summary judgment, alleging that Squires had a continuing obligation to post the escrow, even after the sale to AKCK. Squires responded that its obligation to post the escrow terminated when it sold the property to AKCK. The trial court ruled in favor of the City, and Squires appealed. On appeal, the appellate court reviewed the language of the annexation agreement to determine whether Squires' obligation to post an escrow continued after its sale to AKCK. Based on the language in the annexation agreement that provided that upon assignment of the agreement, Squires would have no further obligations under the agreement, the appellate court reversed the trial court's ruling in favor of the City and ordered the City to refund the $43,000 to Squires. 7. In Eagle Cove Camp & Conference Ctr., Inc. v. Town of Woodboro, 734 F.3d 673, 676 (7th Cir. 2013) cert. denied, 134 S. Ct. 2160 (U.S. 2014), a summer camp operator alleged that the Town of Woodboro and Oneida County violated the camp's constitutional rights and the Religious Land Use and Institutionalized Persons Act (RLUIPA) in prohibiting the camp from running a year-round bible camp on residentially zoned property. The district court ruled in favor of the Town and County, and the camp operator appealed to the Seventh Circuit. The Seventh Circuit affirmed, also ruling in favor of the Town and County. The Town had enacted a land use plan in 1998 that encouraged low density single family residential development along its lake and river-fronts. In 2009, the Town adopted a comprehensive plan that incorporated these goals. The zoning around Squash Lake reflects these goals, and all but seven of the properties in that area were zoned for single family uses. The seven non-residentially zoned lots were grandfathered with pre-existing uses. Eagle Cove wanted to construct a bible camp on 34 acres of property they own on Squash Lake. Those parcels are all zoned for residential and/or residential and farming uses. Eagle Cove filed an application to rezone the property to a recreational zoning district to allow the bible camp. The County denied the rezone petition, and shortly thereafter Eagle Cove sought a conditional use permit to permit the bible camp while maintaining the residential zoning of the property. The Town recommended that the County deny the CUP because it was not consistent with the goals of the comprehensive plan, and the County agreed, denying the CUP. Shortly after the denial of the CUP, Eagle Cove filed suit, claiming violations of various constitutional and federal statutes, including RLUIPA, ADA, the Rehabilitation Act. The County and Town filed motion for summary judgment, which the district court granted. The Seventh Circuit first addressed Eagle Cove's "total exclusion claim" under RLUIPA, finding that the zoning decisions did not preclude Eagle Cove from conducting any religious assembly on the properties, just not in the form of a bible camp. Moreover, Eagle Cove could operate a bible camp in many other parts of the County, just not on this parcel. Second, the Court rejected Eagle Cove's substantial burden claim under RLUIPA, finding that there were numerous other locations within the County for Eagle Cove to place its bible camp. The comprehensive plan was a neutral land use regulation, and Eagle Cove does not get a "free pass" or special treatment on the basis of any religious purpose. Third, the fact that Eagle Cove spent considerable time and money on its various zoning applications does not constitute a substantial burden under RLUIPA. Eagle Cove's "equal terms" claim was also rejected, because the ban on year-round recreational camps applies equally to both religious and secular assemblies 8. In Meridian Village Assn v. Hamer, 2014 IL App (5th) 130078, the court addressed a senior housing facilitys eligibility for a charitable or religious use exemption from property taxes. The senior housing facility, Meridian Village Association, applied to the Department of Revenue for an exemption, but was denied. On appeal, the appellate court first applied the "charitable use" exemption standards for senior housing, and agreed with the Department of Revenue that the senior housing facility did not qualify for an exemption. Although senior housing facilities have qualified for exemptions in the past, they must meet very specific standards, including that the charity benefits an unlimited number of people and that the charity is dispensed to all who need it. Here, the Meridian Village Association's bylaws allowed it to deny care if necessary to operate in a financial manner. It also only provided charitable care to its residents, not all in need. The association also operated for-profit. As to the senior facility's religious exemption claim, the court determined that the primary use of the facility was to care for the elderly, not as a religious institution. 9. In Stone Street Partners v. City of Chicago, 2014 IL App (1st) 123654, the Illinois Appellate Court invalidated a fine imposed by a City of Chicago administrative hearing officer regarding building code violations, because the process used by the City was a civil-procedure disaster. In 1999, a city inspector found several building code violations in plaintiffs building. Plaintiff is a corporation. The city mailed a notice of violation and summons for an administrative hearing to the street address of the building. The city code (and State law) requires that notice and summons be mailed to the registered agent of a corporation, but the city failed to do so. The corporation had no knowledge of the code violations or the administrative hearing. However, someone did receive the notice, because at the scheduled hearing a non-attorney friend of a managerial employee of the corporation, appeared and presented evidence to the hearing officer. The hearing officer found the corporate owner liable for the code violations and fined it $1,050. In 2004 the city registered the fine in court. In 2009 the city filed a lien against the property for the amount of the fine and costs and in 2012 turned the original administrative fine into a judgment of the circuit court. In 2011, the corporation discovered the lien. It attempted to get the original administrative fine vacated on the grounds that the city had failed to notify the registered agent of the corporation. In the meantime, the city had destroyed most of the records of the original hearing, even though it was still attempting to collect the fine. The hearing officer ruled that, for procedural reasons, the 1999 fine could not be vacated. The corporation then filed suit in circuit court, raising several arguments. The circuit court dismissed the complaint and the corporation appealed. The appellate court carefully analyzed the procedures involved in municipal administrative adjudication proceedings and ruled in favor of the corporation. First, the court held that because the city had failed to properly notify the owner of the building, service of process was invalid. Service of process on a corporation must be made on the registered agent. Second, the court held that a non-attorney may not represent a corporation in administrative adjudication proceedings. Representation of a corporation in administrative proceedings constitutes the practice of law and must be made by a licensed attorney. The appellate court allowed the corporation to nullify the original fine twelve years after it was imposed. 10. The United States District Court for the Northern District of Illinois, in Am. Islamic Ctr. v. City of Des Plaines, 13 C 6594, 2014 WL 1243870 (N.D. Ill. Mar. 24, 2014), ruled that city council members are entitled to absolute legislative immunity for their actions on an Islamic organizations application to rezone property. The American Islamic Center (AIC) had been looking for a permanent facility where it could provide religious and educational services since 2011. AIC contracted to buy property in Des Plaines, Illinois in a manufacturing zoning district to conduct these activities in February 2013. The contract to purchase the property was conditioned on it being rezoned to an industrial zoning district where religious and educational activities are permitted. In June 2013, the Des Plaines Plan Commission conducted a public hearing at which it found that rezoning the property would neither significantly harm traffic and parking patterns nor require the expansion of public facilities. It recommended that the Des Plaines City Council adopt the proposed amendment. In July 2013, however, the City Council denied the proposed amendment by a vote of 5 to 3. AIC sued the City of Des Plaines and the five members of the City Council in their individual capacities who voted against the rezoning request. AIC sued under RLUIPA, the United States Constitution, and state law. The only claims brought against the City Council members were violations of the free exercise of religion and the equal protection clause, under the First and Fourteenth Amendments to the U.S. Constitution. AIC argued that the City Council members actions were administrative or executive in nature and not entitled to immunity, as opposed to legislative acts taken in their legislative capacity which are entitled to immunity. However, the District Court found in favor of the City Council members in their motion to dismiss the claims brought against them because they were entitled to absolute legislative immunity. 11. Stivers v. Bean, 2014 IL App (4th) 130255, involved a municipality suing to disconnect certain property from a library district after the village had annexed those parcels. The library district argued that because the village failed to follow all of the required statutory procedures for annexation, the parcels should remain within the library district's jurisdiction. Specifically, the district claimed that the village failed to file affidavits that it had served the library district trustees with the statutorily required notices. The village argued that the district's defenses were barred by the one-year statute of limitations contained in Section 7-1-46 of the Illinois Municipal Code. The trial court agreed with the village, finding that the district was barred from raising procedural deficiencies as a defense after the one year annexation statute of limitations had expired. On appeal, however, the appellate court reversed, finding that statute of limitations bar stale claims, not defenses based on clear language in the statute that bars the commencement of an action to contest an annexation but makes no mention of defending against such a challenge. 12. In People v. Vill. of Glendale Heights, 2013 IL App (2d) 13-0472-U, an appellate court addressed an annexation dispute involving competing municipalities. On August 22, 2012, the Village of Glendale Heights provided notice to taxpayers of record that it intended to forcibly annex certain properties to the Village by ordinance at a meeting scheduled for September 6, 2012. The day before the meeting, the owners of those same properties filed a petition for annexation with the Village of Bloomingdale asking that Bloomingdale annex the property. On September 6, 2012, Glendale Heights adopted an ordinance annexing the properties and recorded a certified copy of that ordinance on September 12. The owners filed aquo warranto lawsuit against Glendale to challenge the annexation. The owners claimed that the voluntary annexation petition submitted to Bloomingdale took priority over the involuntary annexation by Glendale Heights. The trial court agreed, finding that the Bloomingdale annexation had priority. Thetrial courtruled on the basis of thecommon law rule of "priority of annexation" that annexation proceedings must be considered and completed in the order in which they are initiated. Voluntary annexations are considered initiated when an annexation petition is filed. Involuntary annexations, on the other hand,are not"initiated" until the municipality adopts the annexation ordinance. According to the trial court, because the voluntary annexation was initiated the day before Glendale Heights adopted its ordinance, the annexation petition filed with Bloomingdale had priority and Glendale Heights' annexation was void. On appeal, the appellate court first reviewed the various methods of annexation permitted by state law. The process used by Glendale Heights (65 ILCS 5/7-1-13) allows a municipality to forcibly annex territory that is 60 acres or less in size and is wholly bounded by one or more municipalities upon providing mailed notice to the taxpayers of record and others, and publication of notice in the newspaper. That statute also provides that "no other municipality may annex the proposed territory for a period of 60 days from the date the notice is mailed or delivered to the taxpayer of record." There is an exception allowing another municipality to annex the property if a voluntary annexation procedure is initiated prior to publication and mailing of the notices for the involuntary annexation. Although the trial court based its ruling on "priority" rules, the appellate court determined thatpriority was not at issue in this case. Instead, the appellate court determined that thequestion atissue was simply whether Glendale Heights had the authority to annex the territory.The appellate court said yes, finding that Glendale Heights met its burden of showing it complied with 7-1-13 in annexing the territory. The court further stated that it need not address the priority issue because priority only becomes relevant when two municipalities have annexed the same territory - here, only Glendale Heights completed annexation. Consequently, Bloomingdale had no rights in this case, and Glendale Heights' annexation was valid. 13. In CBS Outdoor, Inc. v. Vill. of Plainfield, 12 C 4317, 2014 WL 1678597 (N.D. Ill. Apr. 25, 2014), an outdoor advertising company sued the Village for violations of its due process rights, equal protection of the law, and freedom of speech, where the Village attempted to require the company to remove a billboard. CBS Outdoor owned a billboard on a leased parcel of land which was annexed by the Village. In 2006 the Village amended its sign code so that it stated that billboards or other similar large outdoor advertising devices are expressly prohibited. Subsequently, the owner of the land sought to develop a portion of the land by building a McDonalds restaurant. The Village granted the special use permit the land owner needed however approval was subject to two conditions. One of the conditions was that the sign be removed when the current lease expired. Ultimately, the sign was not removed and the Village wrote to the successor lessor that the property was violating several ordinances including the sign ordinance and that the sign needed to be removed. In response CBS Outdoor filed suit alleging several counts including that the 2006 Sign Code deprives it of its constitutional rights to free speech, and that the removal condition constitutes a deprivation of substantive due process, a deprivation of equal protection of the law, and a deprivation of CBS's freedom of speech. The Village moved to dismiss the complaint for failure to state a claim and the court determined that CBS Outdoors First Amendment claim should survive the Villages motion to dismiss but that its equal protection claim was not adequately pled. 14. In Residences at Riverbend Condo. Ass'n v. City of Chicago, 13 C 4007, 2013 WL 6080685 (N.D. Ill. Nov. 19, 2013), the court determined that 65 ILCS 5/11-13-7, which outlines the procedure for giving notice of application to amend a zoning ordinance, did not create a protected property interest for condominium association and its members. The Riverbend Condominium Association and its members alleged that the City violated its due process rights when it amended the Citys planned development zoning ordinance to allow development of commercial buildings near the condominium building. However, the court determined that their due process rights were not violated because they did not have a protected property interest to begin with. The court explained that their reliance on Section 11137 as providing an independent source of their constitutionally protected property rights is misplaced because the statute outlines the procedure for giving proper notice when applicants apply to amend a zoning ordinance and procedural guarantees, whether relied on or not, do not establish a property interest protected under the Fourteenth Amendment's Due Process Clause. Moreover, the court stated that Illinois courts do not recognize property values, air, or light as constitutionally protected property interests and that the process due in a zoning case is minimal and must normally be pursued in state court. 15. In Mossville Land Investments, LLC v. Peoria Cnty. Bd., 2014 IL App (3d) 130222-U, appeal pending (Sept. 2014), the appellate court upheld the trial courts decision that the countys denial of special use permits was not unreasonable or against the manifest weight of the evidence. Mossville had requested that the Peoria County Zoning Board of Appeals grant it special use permits to develop two pieces of property as a sand and gravel mine. The zoning board, after a hearing, recommended that the county board deny the petitions. The county board adopted the recommendation and denied the request, finding that the special use requirements of the county code had not been met. The trial court, reviewing the matter as an administrative review case, upheld the countys decision. That decision was appealed and subsequently remanded for further proceedings. On remand Mossville challenged the boards ruling as a legislative action and claimed that their due process rights were violated. The trial court applied the factors set forth in La Salle National Bank and Sinclair Pipe Line and affirmed the countys decision. The appellate court considered each of the La Salle factors including (1) the existing uses and zoning of nearby property, (2) the extent to which property values are diminished by the particular zoning restriction, (3) the extent to which diminishing the plaintiff's property values promotes the health, safety, morals and general welfare of the public, (4) the relative gain to the public as compared to the hardship imposed upon the individual property owner, (5) the suitability of the subject property for the zoned purpose, (6) the length of time the property has remained vacant as zoned in the context of land development in the vicinity, (7) the community's need for the proposed use; (8) whether there exists a comprehensive plan, and (9) whether the challenged ordinance is in harmony with the comprehensive zoning plan. The court concluded that the record supports the trial court's conclusion that Mossville failed to prove by clear and convincing evidence that the denial of the special use permits was arbitrary and unreasonable and bore no substantial relation to the public health, safety, or general welfare. Therefore the trial court's finding that the county board's decision was constitutionally valid was not against the manifest weight of the evidence. Due Process Case Law Fox Moraine, LLC v. United City of Yorkville, 960 N.E.2d 1144 (Ill. App. Ct. 2011) Facts: Fox Moraine, LLC appealed an order from the Illinois Pollution Control Board to deny Fox Moraines siting application to construct a landfill in Yorkville. Fox Moraine argued that the hearings on this application were not fundamentally fair, and that the decision that if failed to satisfy the siting criteria of the Environmental Protection Act was against the manifest weight of the evidence. Fox Moraine attempted to build a landfill on some unincorporated land in Kendall County, near the city limits of Yorkville. When negotiations with the county broke down, Fox Moraine attempted to have the land annexed to Yorkville so he could negotiate with the Yorkville corporate authorities. Fox Moraine filed a siting application pursuant to section 39.2 of the Environmental Protection Act (415 ILCS 5/39.2(a)) Yorkville held several public hearings on this matter in March and April 2007, but due in part to a strong public backlash to the landfill, the city council denied Fox Moraines application. The city council formally noted that Fox Moraine did not meet most of the siting criteria set forth in section 39.2 of the EPA. Fox Moraine appealed this decision to the Illinois Pollution Control Board, arguing that the proceedings were fundamentally unfair and that the findings were against the manifest weight of the evidence. Fox argued that the proceedings were fundamentally unfair because: 1) city council members were biased and driven by political considerations which caused them to prejudge the siting application; 2) the council considered information not in the record; 3) the Board incorrectly applied the deliberative process privilege and did not apply the proper standard in determining whether the council members were biased. Holding: The court found that the city council and Boards decision was not against the manifest weight of the evidence. The court held that it was error for the Board not to allow Fox Moraine to view a report by city attorney Mike Roth, but that this error was harmless. The court noted that the report made by Roth was based only on evidence contained in the record. Therefore, although the city council had waived its attorney-client privilege, and therefore Fox Moraine had the right to view Roths report, it would not have obtained any additional information as a result of viewing this report. The court also rejected Fox Moraines argument that the deliberative process privilege no longer applies in Illinois. The court cited Thomas v. Page, 837 N.E.2d 483 (Ill. App. Ct. 2005), as support of its argument that this privilege applies to judicial bodies in Illinois, protecting them from disclosing how they arrived at a decision. The court rejected Fox Moraines argument that it should have been allowed to question council members about comments they made during deliberations meetings, holding that doing so would be unduly burdensome and that these comments did not require further clarification. The court then next noted that there was nothing in the record supporting Fox Moraines argument that the city councils deliberations were fundamentally unfair. It found nothing supporting the contention that the mayor had colluded with attorney Roth to draft a report before the hearing denying the siting approval. The court also noted that fundamental fairness merely required that the record be made available to the city council before it made its decision, and did not require the council members to review it, as Fox Moraine alleges. The court then noted that there was nothing in the record to show that illegal ex parte communications occurred between city councilmen and members of the public. Finally, the court held that the city councils decision on the siting criteria was not against the manifest weight of the evidence. The court found that the councils determination that the clay that would be under the landfill was too permeable was a reasonable conclusion on which to base its decision to reject the application. Stop the Mega-Dump v. Cnty. Bd. of De Kalb Cnty., 979 N.E.2d 524 (Ill. App. Ct. 2012) Facts: Waste Management of Illinois applied for permits to expand a landfill in DeKalb County, exhuming an old section of the landfill and adding hundreds of acres of new capacity. As part of this agreement, Waste Management would pay $120 million to the county over 30 years. The County and Waste Management began negotiating this agreement in 2008, and signed it in March 2009. This did not, however, commit the county to allowing the siting of the landfill to be in the County, and instead stated that the statutory procedures would be followed before a location would be chosen. Stop the Mega-Dump (STMD) challenged the Countys proceedings, arguing that they were fundamentally unfair. STMD claimed that the proceedings were fundamentally unfair because the County Board merely rubberstamped the application because they were desperate for revenue. Public hearings were held over the course of six days by the County regarding the approval of a location for the landfill, required by the Illinois Environmental Protection Act, 415 ILCS 5/39.2(d). The siting of the landfill was approved by both the County and the Illinois Pollution Control Board (PCB). STMD sought reconsideration of the PCBs order, but this was denied. It then appealed the PCBs decision.. STMD argued that the County Boards siting approval proceedings were fundamentally unfair because: 1) the County Boards procedural rules barred the general public from participating in the hearing; 2) Waste Management engaged in improper ex parte communication by taking County Board members on tours of Waste Managements landfill; 3) the County Board was biased toward Waste Managements application and approved it without a fair and impartial review. Holding: The court found that the PCBs decision was not clearly erroneous. The court held that the PCBs determination that the procedures in the siting Ordinance and Articles were not fundamentally unfair was not clearly erroneous STMD challenged sections of the County Boards Articles of Rules and Procedures of the Pollution Control Facility Committee (Articles), which were implemented to govern the Committees application and hearing process. Specifically, it held that section 5 of Article III rendered the public hearing fundamentally unfair by discouraging and limiting public participation, as it did not provide enough people with an opportunity to comment at the public participation hearing. The court disagreed, rejecting STMDs argument that the Articles too narrowly defined the class of individuals allowed to participate in the hearing. The court noted that STMD cited no authority for the proposition that the fundamental fairness guarantees of the Articles afforded all members of the public the right to appear as a party and fully participate. It held that the publics ability to submit written comments satisfied this prerequisite. The court also held that no improper ex parte contacts occurred when the members of the County Board were allowed to tour the landfill at Waste Managements expense. The court noted that the members of the County Board were not judges, but elected officials, so therefore it was expected that they would make contact with the public. The court would only find this contact improper if it can be demonstrated that this led to prejudice. The court held that STMD had the burden of providing specific evidence that the County Board was biased. It failed to do this. STMD also alleged that the hearing was fundamentally unfair because the County Board failed to base its decision on the evidence at the hearing and instead prejudged Waste Managements application The court held that the PCBs decision that this did not occur was not contrary to the manifest weight of the evidence. It also found no evidence supporting STMDs claim that the County was desperate to obtain money to pay for a new jail. Hidden Village, LLC v. City of Lakewood, Ohio, 734 F.3d 519 (6th Cir. 2013) Facts: The Lutheran Metropolitan Ministries (LMM) ran the Youth Re-entry Program (Program), a service that helps young people released from foster care or juvenile detention re-enter society. The Program prepares its clients to live on their own by teaching them how to apply for a job or to find an apartment. About 4/5 of the Programs participants are black. In 2006, the Program moved from Cleveland to Lakewood, Ohio, where it attempted to lease an apartment complex from Hidden Village. Before moving in, the Programs directors met with city officials to explain their mission. At this meeting, Lakewoods Building Commissioner (Commissioner) stated that the location of the facility violated local zoning laws, as it was a prohibited institutional use. The Program disagreed, arguing that it was a permitted residential use, and moved into the Hidden Village apartment complex. The Commissioner responded by ordering the Programs removal, but this was overturned by the Lakewood Planning Commission. However, tensions between the city and the Program continued. The police department sent officers a memo telling them to issue citations to Program members, and the police started to issue jaywalking tickets for astronomically high fines and harassing the Program members in other ways. The mayor also wrote to the LMM, stating that he would seek to have the Program removed at the earliest possible time. As a result of these events, Hidden Village sued Lakewood, the mayor, Commissioner, and a housing and building department advisor. Hidden Village filed suit under 1981, 1982, and 1983, claiming that the defendants discriminated against its tenants on the basis of race. The District court rejected the defendants motion for summary judgment, holding that that the individual defendants did not enjoy qualified immunity. Holding: The appellate court upheld the district courts denial of the defendants motion for summary judgment, finding that Hidden Village had produced enough evidence for a jury to conclude that the City had discriminated against the tenants on the basis of their race. The court noted that emails between city officials revealed a detailed plot to drive the Program out of Hidden Village. The court also held that there was enough evidence for a jury to reasonably conclude that all three individual defendants participated in the effort to drive the Program out of Hidden Village. The court again pointed to the emails that these officials sent to one another describing their goal to kick the Program out of Hidden Village. The court also held that a jury could conclude that race discrimination motivated the three individual defendants. The court again pointed to these emails, and noted that a search conducted by the City focused exclusively on Program tenants, not other tenants. The Court also noted that the white participants in the Program had not complained of harassment, but the black participants had. The court also found that there was enough evidence that the City violated the Fair Housing Act by their discriminatory actions. However, it held that the individual defendants were entitled to qualified immunity. The court, however, did not find that the individual defendants were entitled to qualified immunity on the trespass claims brought against them, because a jury could find that they had acted with malicious intent, which defeats a legislators claim for qualified immunity. Due Process Issue: The court cited Buchanon v. Warley, 245 U.S. 60 in support of the legal principle that the state could not interfere with property rights except by due process of the law. The court noted that if the government attempts to drive residents out of their homes on account of their race, these tenants due process rights have been violated. Scrap Yard, LLC v. City of Cleveland, 513 F. App'x 500 (6th Cir. 2013) Facts: The City of Cleveland and Scrap Yard, LLC had a long-standing zoning dispute over whether Scrap Yard, a business which processed scrap metal, complied with the Citys zoning code. In 2006, the City sued Scrap Yard for a number of zoning violations, claiming that it violated a number of land use ordinances. The City sought a preliminary and permanent injunction against operations at the site. The case wound its way through state court, with an injunction issued by the trial court and then overruled by the appellate court on two occasions. During the state court proceedings, Scrap Yard filed a complaint in federal court. The first complaint was dismissed without prejudice, and the second complaint is the subject of this action. Scrap Yards complaint asserted claims alleging, among other things, a 1983 claim alleging that the Citys enforcement of its zoning code against Scrap Yard violated its Due Process rights, a 1983 claim alleging deprivations of health, safety, privacy, and welfare, and an unlawful taking of property. The court dismissed the claim that the Citys enforcement of its zoning code against Scrap Yard amounted to a civil rights violation Likewise, the court dismissed the allegation of a deprivation of health, safety, privacy, and welfare, noting that Scrap Yard had failed to allege facts to state this claim. Finally, the court held that, with the state law claims pending, Scrap Yards taking claim was not ripe. Due Process Issue: As noted above, the court found that the Scrap Yard suffered no due process violation by the City attempting to enforce its zoning code. M & S Signs, LLC v. Twp. of Au Sable, 2014 WL 103219 (E.D. Mich. 2014) Facts: M&S Signs erects billboards. Between April 2011 and August 2012 it submitted three applications to erect billboards. All three of these were denied, as the municipality claimed that the signs did not comply with its sign ordinance, which limits signs to areas zoned for industrial uses. M&S claimed that this action was a violation of equal protection, a violation of its procedural due process rights, and a violation of free speech. M&S claimed that the action violated its Due Process rights because it fails to circumscribe the time in which government officials must grant or deny a sign permit. Holding: The court held that M&S did not allege a procedural due process claim because it did not allege that it had any protected property interest in receiving the sign permit. In order to allege a procedural due process claim, a plaintiff must establish that: (1) that it has a life, liberty, or property interest protected by the Due Process Clause of the Fourteenth Amendment, (2) that they were deprived of this protected interest within the meaning this clause, and (3) that the state did not afford them adequate procedural rights prior to depriving this protected interest. The court also rejected the argument that the denial of the applications was a violation of M&Ss First Amendment rights because it found the ordinance to which the application did not conform to be a content-neutral, narrowly-tailored ordinance justified by a significant government interest, and that it left open other channels of communication. Finally, the court held that the Equal Protection argument was not yet ripe for disposition. Due Process Issue: As noted above, the Due Process claim failed here because the plaintiff could not allege that it had any protected property interest in receiving a sign permit. A protected property interest must be deprived in order for a Due Process claim to proceed. Embassy Realty Investments, Inc. v. City of Cleveland, 2013 WL 5532646 (N.D. Ohio 2013) Facts: Embassy purchased property from Barnes, who had obtained the property from a church. In 1998, while the property was still owned by the church, the City of Clevelands issued a notice that the church violated zoning ordinances and condemned it. The notice, however, was never recorded. The City took no additional action on the property for nine years. Between 2007 and 2009, Barnes applied for four permits to add to the building. All four were denied, as the Citys zoning division held that the building did not meet zoning codes. Barnes appealed these decisions, seeking variances, but these requests were denied. Embassy also filed an appeal with the zoning board, challenging the validity of the condemnation as it applied to subsequent purchasers. This was denied, and the City tore down the building. Both Barnes and Embassy filed this action, which brought a 1983 claim alleging that the building had been demolished in violation of their right to procedural due process under the Fourteenth Amendment and the right to substantive due process. They also claimed that this demolition violated their Fourth Amendment right to be free from unlawful searches and seizures, and that it constituted an unlawful taking under the Fifth Amendment. Holding: The court granted the defendants motion for summary judgment on the Due Process claim. The court held that the plaintiffs had waived their right to challenge their alleged lack of notice, because they waived this issue when they abandoned their appeal before the zoning board challenging the notice that they received. The court held that the plaintiffs could not complain that the administrative process was inadequate to address the alleged notice violations when they chose not to fully avail themselves of it. Furthermore, the court noted that plaintiffs had full notice of the condemnation before it occurred, and were given a full and fair opportunity to be heard prior to the deprivation. The court also granted the defendants motion for summary judgment on their substantive due process claim. The court noted that substantive due process will only be granted when the government action is arbitrary and capricious or conscious shocking. Here, the Citys decision to demolish a building which it had already condemned was neither. The court also rejected the takings claim. It held that there cannot be a taking where the action remedied a nuisance, which the court held the Citys demolition of the property to do. Due Process Issue: As noted above, the court did not find the Citys action to violate the plaintiffs due process rights because they had received sufficient notice of the condemnation and had received a sufficient opportunity to respond. The plaintiffs also failed to satisfy the high bar required to allege a substantive due process violation. Get Back Up, Inc. v. City of Detroit, 2013 WL 3305672 (E.D. Mich. 2013) Facts: Get Back Up (GBU), a substance-abuse treatment center, sought a permit to operate in one of the citys business zones. This zoning classification allowed a number of larger residential structures like fraternity houses, multi-family dwellings, town homes, and pre-release adjustment centers. The City denied this permit, holding that GBU was not the type of use permitted in this zone. The zoning board of appeals was particularly worried about the reports it received of the GBUs occupants engaging in poor behavior. GBU sued the City, claiming that its action violated the ADA, the FHA, and the Rehabilitation Act. GBU also claimed that the ordinance violated its rights under the Due Process Clause, as it was void for vagueness. Holding: The court held that GBUs Due Process rights were not violated because the zoning ordinance was not void for vagueness. In order for a zoning ordinance to be void for vagueness, it must be so vague as to articulate no rule or standard at all. The court noted that municipalities have broad power to implement zoning regulations, and consequently can pass general and far-reaching ordinances. While the ordinance in this case may have been broad, it was not unconstitutionally so. The court did not find the zoning ordinance to discriminate on its face against the disabled, which would have been required to allege a violation of the ADA. Nothing in the ordinance made any distinction that would discriminate specifically against the disabled. Furthermore, the ordinance was not applied in a manner to discriminate against the disabled. The zoning board had sound reasons to deny GBU a permit to operate in the district that had nothing to do with discrimination against the disabled. 10 & Scotia Plaza, LLC v. City of Oak Park, 2013 WL 300906 (E.D. Mich. 2013) Facts: In 1999, Scotia Express, LLC applied for a liquor license. While this application was pending, the City of Oak Park passed a zoning ordinance that prohibited one business with a liquor license from being within 1,000 feet of another business with a liquor license. Across the street from where Scotia Express sought to locate was a business with a liquor license. Therefore, the City denied Scotias application for a liquor license. In 2010, this space again become empty, and Scotia Express applied for a liquor license. Again, this license was denied, as it was within 1,000 feet of another business with a liquor license. Scotia Express sued, claiming that the denial of the liquor license was intended to give the business across the street an advantage. The complaint contained nine counts, including a 1983 claim of selective enforcement, a claim of a violation of substantive due process, a takings claim, and a claim that the ordinance was unconstitutionally vague. Holding: The court denied the substantive due process claim, holding that the City had a valid reason to enact the ordinance, and that the ordinance did not shock the conscious or constitute arbitrary and capricious action. The court also held that the ordinance was not void for vagueness and thus a violation of the plaintiffs procedural due process rights. The court held that a normal person could understand the ordinance, and that it had a discernable meaning. The court denied the takings claim, holding that it was not ripe for review The court held that Scotia Express was required to go through the proper state law procedures first before it could apply for relief in federal court. The court denied the plaintiffs 1983 claim, holding that the plaintiff had not articulated any viable constitutional claim. Due Process Issue: The court held that there was no viable substantive due process claim, as the plaintiffs had failed to allege that the governments action shocked the conscience. 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