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Coniston Corp. v. Village of Hoffman Estates

United States Court of Appeals for the Seventh Circuit

844 F.2d 461 (1988)

Facts

Coniston Corp. (plaintiff) owned several hundred acres of land within the Village of Hoffman Estates (the village) (defendant). Coniston Corp. presented a site plan for the development of office space on a 17-acre parcel of its land. The village’s ordinances required that site plans for development be first submitted to the village plan commission for its recommendation on the plans and then submitted to the village’s board of trustees for final approval or disapproval. With regard to Coniston Corp.’s site plan, the village plan commission recommended approval of the plan, although it expressed concern with the amount of vacant office space already within the village. The board of trustees then disapproved of the plan without giving a formal reason. However, at least one trustee indicated the decision was based on the amount of unused office space already within the village. Coniston Corp. filed a lawsuit, arguing that its substantive and procedural due-process rights were denied as a result of the village’s disapproval of its site plan. The district court dismissed Coniston Corp.’s complaint for failure to state a claim for which relief could be granted. Coniston Corp. appealed.

Rule of Law

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Issue

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Holding and Reasoning (Posner, J.)

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