Haymarket DuPage, LLC v. Village of Itasca

CourtDistrict Court, N.D. Illinois
DecidedMarch 31, 2025
Docket1:22-cv-00160
StatusUnknown

This text of Haymarket DuPage, LLC v. Village of Itasca (Haymarket DuPage, LLC v. Village of Itasca) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Haymarket DuPage, LLC v. Village of Itasca, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

HAYMARKET DUPAGE, LLC, ) ) Plaintiff, ) Case No. 22-cv-160 ) v. ) Hon. Steven C. Seeger ) VILLAGE OF ITASCA, et al., ) ) Defendants. ) ____________________________________)

MEMORANDUM OPINION AND ORDER

Haymarket DuPage, LLC wanted to open a treatment facility for substance abuse in the Village of Itasca. Haymarket tried and tried to get approval, over a span of two years. Hearing after hearing, discussion after discussion, and protest after protest followed. But in the end, the Itasca Plan Commission voted it down. Haymarket responded by suing the Village and a number of its departments and officials, bringing a collection of disability-based discrimination claims under federal and state law. The United States later filed a motion to intervene as a plaintiff. For the reasons stated below, the motion to intervene is denied. Background This Court already issued a lengthy opinion at the motion-to-dismiss stage. See 2/27/24 Mem. Opin. & Order (Dckt. No. 61). This Court assumes that any interested reader is familiar with the background. In a nutshell, Haymarket DuPage, LLC is Chicagoland’s “largest and most comprehensive non-profit provider of treatment for substance use disorders and mental health disabilities.” See Am. Cplt., at ¶ 3 (Dckt. No. 81). Haymarket wanted to open a new facility in an old Holiday Inn hotel in the Village of Itasca, a town in DuPage County. Haymarket sought zoning approval from the Village. See Mtn. to Intervene, at ¶ 1 (Dckt. No. 94). The Village denied Haymarket’s request. Id. Haymarket then sued the Village, bringing eight claims, including a claim under Title II

of the Americans with Disabilities Act (“ADA”). Several Defendants moved to dismiss. This Court granted those motions and dismissed three Defendants. See 2/27/24 Mem. Opin. & Order (Dckt. No. 61). Haymarket then filed an amended complaint. See Am. Cplt. (Dckt. No. 81). Haymarket brings five claims against the Village, the Itasca Plan Commission, and the Mayor in his official capacity. The five counts include two claims under the Fair Housing Act, one claim under the ADA, one claim under the Rehabilitation Act, and one claim under state law. Meanwhile, the United States opened an investigation into the Village’s compliance with Title II of the ADA. The United States ultimately moved to intervene as a plaintiff in

Haymarket’s case against the Village. See Mtn. to Intervene, at ¶ 3 (Dckt. No. 94). The United States attached a proposed complaint with two claims, including a disparate-treatment claim under the ADA, and a claim about a failure to provide reasonable accommodations under the ADA. See Cplt. in Intervention (Dckt. No. 94-1). Both claims fall under Title II of the ADA. Id. at ¶ 1 (“The United States brings this disability rights enforcement action against the Village of Itasca, Illinois, for violating Title II of the Americans with Disabilities Act of 1990.”). The motion to intervene prompted a number of states to file an amicus brief opposing intervention. See Amicus Brf. of Fifteen States (Dckt. No. 117-1). Analysis “Intervention provides a mechanism for non-parties to protect interests that might otherwise be adversely affected by a trial court judgment.” iWork Software, LLC v. Corp. Express, Inc., 2003 WL 22494851, at *1 (N.D. Ill. 2003) (citing Felzen v. Andreas, 134 F.3d 873, 874 (7th Cir. 1998)).

The Federal Rules recognize two types of intervention: intervention as of right, and permissive intervention. See Fed. R. Civ. P. 24(a) (“Intervention of Right”); Fed. R. Civ. P. 24(b) (“Permissive Intervention”). The non-party who hopes to intervene has the burden to satisfy all of the requirements. See Vollmer v. Publishers Clearing House, 248 F.3d 698, 705 (7th Cir. 2001). The United States seeks to join the case through both routes, so this Court will walk down each path. In the end, both routes are dead ends. I. Intervention as of Right The first question is whether the government can intervene as of right. See Fed. R. Civ.

P. 24(a)(2). A district court “must” allow a non-party to intervene if that non-party “claims an interest relating to the property or transaction that is the subject of the action, and is so situated that disposing of the action may as a practical matter impair or impede the movant’s ability to protect its interest, unless existing parties adequately represent that interest.” See Fed. R. Civ. P. 24(a)(2). The Seventh Circuit has interpreted that rule to impose four requirements for intervention as of right: “(1) timely application; (2) an interest relating to the subject matter of the action; (3) potential impairment, as a practical matter, of that interest by the disposition of the action; and (4) lack of adequate representation by the existing parties to the action.” See Planned Parenthood of Wis., Inc. v. Kaul, 942 F.3d 793, 797 (7th Cir. 2019) (citation omitted); Illinois v. City of Chicago, 912 F.3d 979, 984 (7th Cir. 2019). The proposed intervenor must satisfy all four requirements. See Kaul, 942 F.3d at 797; Vollmer, 248 F.3d at 705. But if the proposed intervenor satisfies all four requirements, a district

court “must” allow the party to intervene. See Fed. R. Civ. P. 24(a)(2). Here, the United States gets tripped up on two of the four hurdles. The government lacks an interest relating to the subject matter of the action. And the existing parties are adequately representing any interest that the United States may have in this case. A. An Interest in the Subject Matter The first problem for the government is the lack of a legally protectable interest in this particular dispute. Rule 24(a)(2) provides that the intervenor must have an “interest relating to the property or transaction that is the subject matter of the action.” See Fed. R. Civ. P. 24(a)(2).

“Intervention as of right requires a would-be intervenor to have a ‘direct, significant, and legally protectable interest in the [subject] at issue in the lawsuit.’” Bost v. Illinois State Bd. of Elections, 75 F.4th 682, 687 (7th Cir. 2023) (citation omitted); see also 7C Mary K. Kane, Federal Practice & Procedure § 1908.1 (3d ed. 2024) (“If there is a direct substantial legally protectable interest in the proceedings, it is clear that this requirement of the rule is satisfied.”). The Seventh Circuit has explained that the intervenor’s interest must be “unique.” See Bost, 75 F.4th at 686–87. The idea is simply that the intervenor must have its own interest. The interest must be “based on a right that belongs to the proposed intervenor rather than to an existing party in the suit.” Id. at 687 (citation omitted). The Seventh Circuit has “never required a right that belongs only to the proposed intervenor, or even a right that belongs to the proposed intervenor and not to the existing party.

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Haymarket DuPage, LLC v. Village of Itasca, Counsel Stack Legal Research, https://law.counselstack.com/opinion/haymarket-dupage-llc-v-village-of-itasca-ilnd-2025.