Plaintiffs are 2 nonprofit organizations operating within Chicago and Illinois. Plaintiffs alleged that City, for over 30 years, has illegally administered Tax Increment Financing (TIF) program in a racially and ethnically discriminatory manner. Plaintiffs claim that City designated areas as TIF districts that were not blighted or in danger of becoming blighted and that were already experiencing or likely to experience economic growth, in predominantly white areas of the City, near other thriving and affluent neighborhoods. The fact that Plaintiffs reallocated their resources to counter the effects of City's actions does not represent a palpable and distinct injury to Plaintiffs, as the reallocation of resources is inherent in the operations of such organizations. An organization's diversion of resources, without more, is not an injury sufficient to confer standing. As complaint alleged no impairment of its provision of services or performance of its activities, court properly dismissed complaint with prejudice for lack of standing. (COBBS, concurring; PUCINSKI, dissenting.)
Illinois Appellate Court
Civil Court
Standing