Left Field Media LLC v. City of Chicago

Federal 7th Circuit Court
Civil Court
Damages
Citation
Case Number: 
No. 19-2904
Decision Date: 
May 15, 2020
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Dist. Ct. did not err in dismissing plaintiff's action for failure to establish existence of any damages, where plaintiff alleged defendant's ordinance improperly requiring it to obtain permit to sell magazines on streets adjacent to Wrigley Field. During pendency of action, defendant amended ordinance to eliminate plaintiff's requirement to obtain said permit, and while plaintiff alleged that it was entitled to receive damages to compensate it for injuries prior to defendant's amendment of ordinance, plaintiff, as business entity, could not assert any emotional damages as claimed by plaintiff, where: (1) entity cannot experience any emotional damages on its own; and (2) any alleged damages were attributed only to plaintiff's owner. Also, plaintiff could not receive compensation for time spent by its owner in researching details regarding compliance with original ordinance, where: (1) owner was already paid full-time salary to perform work on plaintiff's behalf; and (2) plaintiff failed to show existence of some other marginal expense connected to litigating instant case. Moreover, plaintiff could not assert any legal fees, where plaintiff had failed to file any affidavit regarding legal expenses incurred in effort to comply with original ordinance.