Chicago United Industries, Ltd. v. City of Chicago

Dist. Ct. did not err in granting defendant-City’s motion for summary judgment in action alleging that defendant deprived plaintiff-certified minority-owned business enterprise (MBE) of its property without due process by drastically reducing its purchases from defendant for five-month period, which caused plaintiff to incur net loss during same period. Instant five-month reduction was insufficient to constitute destruction of plaintiff’s MBE certificate since defendant still awarded plaintiff new business and continued existing contracts that totaled $939,000. Fact that plaintiff incurred temporary loss while defendant investigated possibility that plaintiff had violated MBE process by becoming broker, as opposed to wholesaler, did not require different result where plaintiff had failed to show that defendant violated any term of plaintiff’s MBE certification during its investigation of plaintiff.