Ruisard v. The Village of Glen Ellyn 

Plaintiffs filed suit against Village and cell phone company, alleging that in granting special-use permit to cell phone company to install 9 additional antennae on tower (when 13 had been placed there previously) was a violation of ordinances passed by Village 16 years ago which granted special-use permit for construction of water tower, subject to the condition that "antennas on the tower are to be kept at a minimum". Plaintiffs have standing, as Municipal Code provides that an owner must show that his property or person will be substantially affected by the alleged violation, and need not prove any specific, special or unique damages. Claim of injuries caused by exposure to RF levels is preempted by the Telecommunications Act. The phrase "at a minimum" in ordinance is ambiguous, and thus court gives deference to the Village's interpretation. Plaintiffs failed to state a claim that the "at a minimum" requirement was violated. (O'MALLEY and HUDSON, concurring.)