Parvati Corp. v. City of Oak Forest

Dist. Ct. did not err in granting defendant-City’s motion for summary judgment in sections 1981 and 1982 action alleging that defendant failed to grant plaintiff’s request to amend zoning ordinance on account of race where buyers of plaintiff’s hotel sought permission to operate hotel as retirement home that would house mostly African-American residents. Current and prior zoning classification of property did not allow for instant proposed residential use, and plaintiff failed to present evidence that defendant had allowed any retirement home catering to white residents in present zoning classification. Moreover, record demonstrated rationality in defendant’s decision not to approve special use for retirement home in current heavy industrial district.