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1
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COMPLAINT
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EXTRACTED KEY WORDS
GROUP HOME CHICAGO HEIGHTS THRESHOLDS PERMIT ZONING RESIDENTS MENTAL ILLNESS UNITED STATES HOUSING ACT MEETING CITY COUNCIL FAIR HOUSING ACT ZONING ORDINANCE DISCRIMINATORY ILLINOIS COMMUNITY PROVISION LAND PROPOSED GROUP HOME DENY VIOLATION PRACTICES REASONABLE ACCOMMODATION OPPOSITION RECOMMEND APPEALS RIGHTS ATTORNEY FEET |
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
CITY OF CHICAGO HEIGHTS,
Defendant.
__________________________________
COMPLAINT
1. This action is brought by the United States to enforce the
provisions of the Fair Housing Act, as amended, 42 U.S.C.
3601 et seq.
2. This court has jurisdiction over this action under 28 U.S.C.
§ 1345 and 42 U.S.C. § 3614(a).
3. Defendant City of Chicago Heights is located in Cook County,
Illinois, and is organized under the laws of the State of
Illinois.
4. The City of Chicago Heights exercises zoning and land use
authority over land within its boundaries. The City of Chicago
Heights' Zoning Ordinance contains the City's zoning and land use
regulations.
5. Section 7-1.2 of the Chicago Heights Zoning Code permits, in
single-family residential districts, group homes in which not more
than eight persons who are disabled may live together with paid
professional staff, provided the group home obtains a Certificate
of Occupancy. A new zoning ordinance was passed by the City
Council on December 21, 1998, but the above-cited ordinance was in
effect at the time of the events giving rise to this action.
6. There are two requirements for a Certificate of Occupancy, one of
which is that the group home "is located at least one thousand
(1000) feet from another group home, except when a special use
permit is issued to allow a (group home) to locate closer than one
thousand (1000) feet to an existing (group home)."
7. The Thresholds, Inc. ("Thresholds") is a corporation organized
under the laws of Illinois. It is in the business of providing
psycho-social services to individuals with mental illness,
including establishing group homes and other residential settings
in which persons with mental illness can live, aided by
professional staff.
8. In May, 1995, Thresholds informed the City of Chicago Heights by
letter that it was considering two parcels of land in the City on
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