Protect Our Parks, Inc. and Maria Valencia filed a lawsuit against the City of Chicago and the Chicago Park District to try stop construction of the Obama Presidential Center in Chicago’s Jackson Park. The plaintiffs claimed that the Obama Presidential Center project does not serve the public interest but rather the private interest of its sponsor, the Barack Obama Foundation. Specifically, they argue that the defendants violated Illinois’ Public Trust Doctrine by transferring control of public parkland to the Obama Foundation for a purely private purpose. They also argue that the defendants acted beyond their legal authority when they entered into a use agreement with the Foundation, violated the Fifth Amendment’s “Takings Clause” by taking plaintiffs’ property for a private purpose, and violated plaintiff’s due process rights.
The Seventh Circuit recently issued a ruling in this case finding in favor of the defendants on the federal law claims (takings and due process claims), and sending the case back to the district court to dismiss the state law claims (public trust and authority claims). Protect our Parks, et al. v. Chicago Park District, et al.
On the federal law claims, the Seventh Circuit determined that plaintiffs did not have adequate standing to bring those claims. The Court rejected plaintiffs’ argument that it had standing based on its status as taxpayers, finding that the plaintiffs failed to show that they would suffer special damage different than what the public at large would suffer. In addition, since the construction of the project is privately funded rather than funded by the City, it wasn’t clear how taxpayers would be injured for purposes of finding “standing” to challenge the project. In addition, plaintiffs did not establish any private property interest in Jackson Park for their federal law claims. Finally, the Court rejected plaintiffs’ takings and due process claims, finding no merit to their substantive arguments.
In sum, the Seventh Circuit upheld the district court’s summary judgment ruling in favor of the defendants on the plaintiffs’ federal claims, but ruled that the district court should have dismissed plaintiffs’ state claims for lack of jurisdiction, and remanded the case back to the district court.
Post Authored by Joyce Jezeer & Julie Tappendorf, Ancel Glink