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Black v. Village of Park Forest

20 F. Supp. 2d 1218 (1998)

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Black v. Village of Park Forest

United States District Court for the Northern District of Illinois
20 F. Supp. 2d 1218 (1998)

  • Written by Jack Newell, JD

Facts

Debra Taylor (plaintiff) was a resident of the Village of Park Forest (the village) (defendant). The village had a policy of performing regular inspections of the interiors of single-family homes that were not owner occupied. The village claimed properties that were not owner occupied had higher rates of code violations. The village also performed exterior inspections of multifamily homes and common-area searches of apartment buildings. The village contacted Taylor’s landlord to arrange for a town inspector to come by and inspect Taylor’s single-family home. The landlord refused to allow an inspection. The inspector came to the house when no one was home and left a note that a search warrant had been issued. The village then petitioned for Taylor and her landlord to be held in contempt of court in the Cook County Circuit Court. Taylor and a group of other residents sued in federal district court, challenging the constitutionality of the village’s residential-inspection policy under the Fourth Amendment. The village claimed that its inspections were administrative searches, and so the searches could be conducted as long as they were governed by reasonable standards.

Rule of Law

Issue

Holding and Reasoning (Gottschall, J.)

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Administrative Law

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