U.S. Department
of Justice
United States v. City of Springfield (C.D. Ill.)
On December 5, 2023, the United States District Court for the Central District of Illinois entered a permanent injunction against the City of Springfield, Illinois, prohibiting it from enforcing a local spacing ordinance that bans people with disabilities from living in homes within 600 feet of one another if the home has five or fewer residents. The court also awarded the United States $61,982.50 in civil penalties against the city for violating the Fair Housing Act. In awarding civil penalties against the city, the court recognized that the city’s attempts to close the home and its restrictive zoning ordinance impeded the integration of people with disabilities from institutions into the community, a right guaranteed by the Supreme Court’s 1999 decision in Olmstead v. L.C. As the court explained, the civil penalty award against the City of Springfield will “make clear to municipalities that these facially discriminatory spacing rules may not be used to hinder the trend of shifting persons with disabilities from institutions to community-based residences.” The court further permanently enjoined the city from taking any action against the owners or residents of the home, ordered the city to undergo fair housing training and awarded $53,654,50 in prejudgment interest on the jury’s damages award to IAG.
On July 26, 2022, a federal jury had awarded $293,000 in damages against the City of Springfield, Illinois, for attempting to close down a small home for three persons with developmental disabilities in 2016. The jury trial was to determine what damages should be awarded for any harm caused by the City’s conduct, and the jury determined that the City should pay a total of $293,000: $162,000 in compensatory damages to the residents of the home and their guardians, and $131,000 in compensatory damages to Individual Advocacy Group (IAG), the state-licensed provider of community residential services at the home. The United States filed its complaint against the City of Springfield in 2017, alleging that the City had discriminated on the basis of disability in violation of the Fair Housing Act (FHA). In 2020, the court entered judgment against the City, holding that the City had violated the FHA by enforcing an ordinance requiring that homes for persons with disabilities, known as Community Integrated Living Arrangements, or “CILAs,” be spaced at least 600 feet apart in the city, granting the United States’ and IAG’s motions for summary judgment on liability. In that ruling, the court held that Springfield engaged in a pattern or practice of discrimination, by imposing the rule on homes of five or fewer persons with disabilities, but not on comparable homes of non-disabled persons. The court also held that by maintaining and enforcing this ordinance, Springfield denied rights under the FHA to a group of persons and that “the availability of community-based housing for persons with disabilities is most assuredly an ‘issue of general public importance.’” The court further held that Springfield violated the FHA by refusing to make a reasonable accommodation for the home with three residents with intellectual and physical disabilities to stay in their home and ordered Springfield to submit a remedial plan to cure all these violations of the FHA. The district court had granted IAG a preliminary injunction in 2017 to prevent the City from shutting down the home, a decision that was affirmed by the Seventh Circuit Court of Appeals. The United States had participated as amicus in that appeal.
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