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Friends of the Parks v. Chicago Parks District

786 N.E.2d 161 (2003)

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Friends of the Parks v. Chicago Parks District

Illinois Supreme Court
786 N.E.2d 161 (2003)

RW

Facts

The City of Chicago erected its Soldiers Field stadium on city-owned park land. The stadium opened as a public-events venue in 1924. For decades, the stadium also hosted the privately owned Bears football team’s home games. In 1970, Illinois adopted a constitution incorporating the public-purpose and public-trust doctrines, as well as a “three-readings” requirement mandating that new laws receive legislative consideration on three separate days. In 2001 the Chicago Parks District (district) (defendant), with the Bears’ support, persuaded the Illinois legislature to enact an enabling statute authorizing the stadium’s publicly financed renovation. Friends of the Parks (Friends) (plaintiff) sued, contending that the statute primarily served the Bears’ private interests, thereby unconstitutionally violating the public-purpose and public-trust doctrines. Friends also contended that the legislature unconstitutionally enacted the statute without complying with the three-readings requirement. The trial court dismissed the suit on the grounds that the statute contained a legislative finding that the statute complied with all constitutional requirements and would primarily benefit the public by facilitating public events and promoting economic growth.

Rule of Law

Issue

Holding and Reasoning (Kilbride, J.)

Concurrence (Freeman, J.)

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