Dist. Ct. did not err in dismissing plaintiffs-land developers’ action alleging that defendants-members of County Commission delayed approval of their plans to develop subdivision in retaliation for plaintiffs’ support in 1996 of political opponent of one member of Commission. Nine-year gap between 1996 election and instant approval of subdivision plans was too long to support any causal connection between protected conduct and alleged retaliatory act. Moreover, plaintiff failed to establish that relevant County Commissioner was even aware of plaintiffs. Also, instant delay in approval of plaintiffs’ plans was attributable to environmental and zoning concerns contained in plans. Fact that approval process took over two years did not require different result.
Federal 7th Circuit Court
Civil Court
First Amendment