Valencia v. City of Springfield, Illinois

The City of Springfield (city) (defendant) had a zoning code designating certain areas as residential districts. In residential districts, residents could use their homes as single-family detached residences or as family-care residences. The code defined a single family as a unit of one or more people related through blood, marriage, or adoption or as a group of fewer than five unrelated people occupying a single dwelling. A family-care residence was defined as a single dwelling occupied on a relatively permanent basis in a family-like environment by a group of fewer than six unrelated people with disabilities and their paid, professional support staff provided by a sponsoring agency. A family-care residence had to be more than 600 feet away from similar residences in order to keep such residences from adversely affecting residential environments through over-population. Individual Advocacy Group, Inc. (IAG) (plaintiff) was a nonprofit organization that provided residential staff for disabled clients, allowing the clients to live in residential communities rather than assisted-living facilities. Such a living arrangement was called a community integrated living arrangement (CILA). IAG’s clients rented individual dwellings, and IAG provided in-home support staff. Three IAG clients (Noble residents) (plaintiffs) lived in a CILA on Noble Avenue (Noble home), but the CILA was unknowingly established within 600 feet of another family-care residence. The Noble residents applied for a conditional zoning waiver to continue operating. At hearings, testimony established that the Noble home had no contact with the other care residence, made no requests of the city, and had used no emergency services during the years it had operated. The waiver was denied, and the Noble residents filed suit in federal district court for discrimination under the Americans with Disabilities Act. The Noble residents sought a preliminary injunction to keep the city from evicting them, and the district court granted the injunction. The city appealed to the Seventh Circuit.