Allegro Services v. Metropolitan Pier and Exposition Authority

The uniformity clause of the Illinois Constitution (Ill. Const. art. IX, § 2) stated that nonproperty tax classifications must meet certain requirements. The Metropolitan Pier and Exposition Authority (the authority) (defendant) developed a project (the expansion project) to expand McCormick Place, a convention center in Chicago. The authority issued municipal bonds to finance the expansion project. In order to repay the bonds, the authority imposed a tax (the airport-departure tax) on businesses that provided ground-transportation services from Chicago’s O’Hare and Midway Airports. Allegro Services, Ltd. (Allegro) (plaintiff) was one of the businesses subject to the airport-departure tax. Allegro’s vehicle operators provided airport-transportation service exclusively to destinations outside of Chicago. Allegro brought suit, contending that the airport-departure tax violated the uniformity clause. Allegro argued that its vehicle operators were differently situated from those who transported passengers from the airports to destinations in Chicago. According to Allegro, operators who served destinations within Chicago would economically benefit from increased tourism related to the expansion project, whereas Allegro’s operators would not enjoy this benefit. But research indicated that the heightened demand for Chicago hotels due to the expansion project would divert some visitors to hotels outside Chicago. Consequently, there would be increased demand for transportation from the airports to hotels outside Chicago. The trial court granted summary judgment in favor of the authority. Allegro appealed.