Weaponization of Code Enforcement

The American right to petition government is expansive, and necessarily so. Less settled is what happens when that machinery built to investigate public grievances becomes a means of imposing private costs.

In the village of Monee, Illinois, a dispute over the enforcement of municipal ordinances became the subject of a federal civil-rights lawsuit. Kenneth Thompson Sr., a property owner who alleged that local officials and private residents had subjected him to a prolonged campaign of scrutiny, described an accumulation of warnings, citations, and fines that eventually exceeded 140 separate enforcement actions and $15,000 in penalties. The matters reportedly involved familiar subjects of local regulation, including vehicles parked on grass, garbage containers, noise, outdoor burning, and conditions at an investment property. In his account, however, the significance of the individual allegations lay in their accumulation. What might have appeared, examined separately, to be ordinary exercises of municipal authority had become, he maintained, an instrument of retaliation. The litigation raised a difficult question about the relationship between private complaints and public enforcement, particularly when an institution with legitimate investigative powers is repeatedly drawn into a conflict whose origins and purposes it may not fully understand.

The distinction between Thompson's allegations and what the courts had established is essential. In the judicial ruling described in the existing record, the district court dismissed claims against the private neighbors while permitting certain claims against municipal defendants to proceed. Such a ruling evaluates whether pleaded allegations can support legal claims; it does not establish that the alleged misconduct occurred. The allegations concerning retaliation, selective treatment, and coordinated conduct remained disputed. Nevertheless, the litigation illustrates a problem that extends well beyond one Illinois municipality. A government agency may be empowered to investigate a suspected violation, and a citizen may be entitled to report it, without either fact resolving whether the resulting investigation is justified in scope, proportionate in its demands, or susceptible to manipulation by someone seeking an advantage unrelated to the law being enforced. The central difficulty lies in the distance between the authority to initiate a process and the consequences experienced by the person required to answer it.

American administrative institutions depend on information supplied by the public. Local governments could not independently observe every potentially dangerous structure, unpermitted improvement, environmental hazard, or nuisance within their jurisdictions, and citizens frequently possess knowledge that officials would otherwise lack. The complaint is therefore both a practical instrument of regulation and an expression of political participation. Its accessibility serves an important democratic purpose, allowing people with limited resources to seek governmental intervention without first retaining counsel or assembling the evidence necessary to prevail in court. Yet accessibility also creates an asymmetry that becomes consequential when the person submitting a complaint and the person investigated do not share the costs of the resulting procedure. Reporting a suspected violation may require little more than completing a form. Responding to the investigation may involve locating historical records, obtaining surveys, retaining professional assistance, appearing at hearings, or demonstrating compliance with technical requirements whose application is itself disputed. The burden can become substantial before any official determines that the underlying allegation has merit.

The possibility that government procedures might be employed principally for the burdens they impose is neither new nor confined to residential regulation. American courts have encountered related questions in disputes involving commercial competition, labor relations, licensing, and access to administrative tribunals. What makes the problem difficult is that the outward characteristics of abusive and legitimate proceedings may be nearly identical. Both can involve technically accurate allegations, formally authorized requests, and officials acting within their jurisdiction. A person may seek enforcement because a condition presents a genuine danger, because a regulation serves a legitimate public purpose, because the condition is personally objectionable, or because an investigation will impose costs on someone the complainant wishes to disadvantage. These motives can coexist, and their presence does not necessarily determine whether the government should act. The law has accordingly developed strong protections for petitioning, while placing significant limits on efforts to impose liability merely because a complaint was antagonistic, unsuccessful, or expensive to defend.

A particularly revealing dispute reached the Supreme Court in 1972. In California Motor Transport Co. v. Trucking Unlimited, established transportation companies were accused of coordinating administrative and judicial challenges to prevent competitors from securing operating authority. The allegation was not simply that incumbent carriers opposed the expansion of rival businesses, an objective that could lawfully motivate participation in regulatory proceedings. Rather, the plaintiffs described a concerted strategy of repetitive and allegedly baseless objections intended to obstruct access to the agencies and courts responsible for considering their applications. The distinction concerned the function of the proceedings themselves. Regulatory review was ostensibly a means of deciding whether a business should receive operating authority; the alleged strategy sought to make the review process an obstacle regardless of the merits of any particular application. The Supreme Court recognized that the constitutional protection afforded to petitioning extends to administrative agencies, but it also acknowledged that a pattern of proceedings designed to deny competitors meaningful access to governmental decision-making could fall outside the protection ordinarily afforded to genuine petitions. The Court permitted the antitrust allegations to proceed without deciding whether the defendants had actually engaged in the conduct described.

The importance of California Motor Transport lies less in its commercial setting than in the institutional mechanism it exposed. A private party need not possess the power to deny a permit, suspend a license, or prohibit an activity if it can instead induce a public authority to undertake proceedings that delay or burden the person seeking approval. The costs of official review may become a competitive advantage even where the challenger cannot ultimately secure the governmental decision it wants. But the doctrine also illustrates the difficulty of identifying improper petitioning without discouraging legitimate participation. The Supreme Court's subsequent decision in Professional Real Estate Investors, Inc. v. Columbia Pictures Industries, Inc. (1993) imposed a demanding standard for the sham-litigation exception to antitrust immunity. Before examining whether a lawsuit concealed an attempt to interfere with a competitor through the governmental process, a court must determine whether the litigation was objectively baseless, meaning that no reasonable litigant could realistically expect success. The subjective desire to injure an opponent cannot, by itself, transform a reasonably based lawsuit into an antitrust violation.

These decisions do not establish a universal legal test for complaints submitted to municipal code-enforcement offices. Their rules arose in antitrust litigation, and the applicability of petitioning immunity or analogous protections to other proceedings depends on the relevant jurisdiction, the nature of the petition, and the cause of action asserted. They nevertheless illuminate a constitutional dilemma that administrative reform cannot avoid. Citizens often seek government action for reasons that are intensely personal, commercially advantageous, or openly hostile to another person's interests. The First Amendment does not ordinarily require petitioners to demonstrate benevolence before asking officials to act. A regulatory objection may be motivated by self-interest and still identify a genuine violation. An unsuccessful proceeding may have been reasonably pursued, and an inconvenient investigation may have been necessary. Any system that equates hostility with abuse would give officials considerable power to discredit complaints based on their perception of the complainant rather than the substance of the allegation.

The difficulty, then, is not simply to identify bad motives. It is to understand how administrative systems translate allegations into obligations, and whether the burdens they impose remain proportionate to the public interests at stake. This requires attention to an aspect of regulation that conventional discussions of enforcement often overlook: the considerable work involved in proving that an accusation is unfounded, that a condition is lawful, or that a government agency has misunderstood its own records. The eventual disposition of a case reveals relatively little about these intermediate costs. An investigation that ends without a citation may nevertheless have required expenditures that cannot be recovered. A notice withdrawn after professional review may have compelled a homeowner to commission that review in the first place. A licensing complaint dismissed for insufficient evidence may have consumed weeks of a professional's time. None of these outcomes establishes misconduct by the person who initiated the proceeding, but each demonstrates that the costs of governmental scrutiny exist independently of the final sanction.

Public-administration scholars have developed a useful framework for examining these burdens. In a 2015 article in the Journal of Public Administration Research and Theory, Donald Moynihan, Pamela Herd, and Hope Harvey distinguished among the learning, compliance, and psychological costs that people experience when interacting with government. Learning costs arise from discovering what the state requires and how its procedures operate. Compliance costs involve the time, money, documentation, and practical effort necessary to satisfy those requirements. Psychological costs include the uncertainty, stigma, stress, and loss of autonomy that can accompany consequential administrative encounters. Although the framework was not developed specifically to study retaliatory municipal complaints, it provides a more precise account of why the absence of a final penalty does not establish the absence of harm. It also directs attention away from the formal equality of a procedural requirement toward the very different capacities of individuals to satisfy it.

Consider the evidentiary problem presented by a longstanding improvement to an older property. A contemporary ordinance may establish a particular dimensional restriction, while the legality of an existing structure may depend on when it was built, what rules applied at the time, whether a permit was required, and whether subsequent changes altered its legal status. The relevant records may be incomplete or divided among municipal departments. A homeowner asked to establish compliance may have to obtain a survey or reconstruct a history that government itself cannot readily document. In some circumstances those demands will be justified; in others, an agency may already possess information sufficient to resolve the matter without imposing additional expense. The administrative question is whether officials have selected a reasonable means of determining compliance, rather than transferring every uncertainty in the government's records to the person under investigation.

The distribution of these costs also complicates the conventional assumption that a uniform procedure is necessarily a fair one. A property owner with professional representation and sufficient financial resources may treat a document request as an inconvenience to be delegated. Someone with limited income, irregular working hours, a disability, or substantial caregiving responsibilities may encounter the same request as a serious practical obstacle. An agency need not intend to disadvantage anyone for its procedures to impose unequal burdens. Nor does that inequality prove that the original complaint was abusive. It does, however, reveal why procedural proportionality is a substantive concern rather than a matter of administrative courtesy. The expense of establishing compliance can be meaningful even when the law ultimately requires no corrective action, and the person who initiated the inquiry ordinarily bears none of that expense.

A system vulnerable to strategic exploitation need not be corrupt or unusually aggressive. It may simply process allegations in a manner that fails to distinguish independent evidence from repeated assertions. This problem has become increasingly important as municipalities have expanded digital reporting platforms and centralized service-request systems. Such technologies improve access, preserve records, and allow officials to identify problems that might otherwise remain invisible. They also encourage governments to treat complaint volume as a measure of demand. That measure is useful, but it can be misleading when the frequency of reporting reflects the behavior or resources of the people submitting complaints rather than the seriousness of the conditions reported. A collection of reports is not necessarily a collection of independently verified facts, and a system that fails to preserve the distinction risks allowing the patterns of public participation to shape enforcement priorities without adequate examination of underlying need.

Research into urban service reporting provides evidence of this problem. In a study published in Sustainable Cities and Society, Constantine Kontokosta and Boyeong Hong examined more than half a million 311 reports in Kansas City, Missouri, alongside neighborhood characteristics, resident-survey information, code-enforcement data, and objective assessments of street conditions. Their findings indicated that lower-income and minority neighborhoods were less likely to report certain problems despite greater measured need. The significance of the research is not that frequent complainants were shown to be acting improperly. It is that the administrative record reflected differences in reporting behavior that could not be explained by differences in the conditions themselves. If a government relies heavily on complaint volume to determine where intervention is necessary, it may respond most readily to the places and people most capable of generating reports, rather than to the places where independent evidence demonstrates the greatest need.

The implications are especially important when a reporting system receives repeated allegations about the same condition. Several complaints may indicate a serious unresolved problem, a failure of the government to respond, a recurrence after earlier corrective action, or the submission of substantially identical information. Those possibilities require different administrative responses. A municipality that automatically opens a new investigation whenever another report arrives may create unnecessary duplication. One that automatically rejects repeated reports may overlook new evidence or a genuine hazard that previous officials failed to address. The difficulty cannot be solved by counting complaints alone. It requires an intelligible record of the condition alleged, the evidence previously examined, the findings reached, and the circumstances that justify further review.

In February 2026, Chicago's Office of Inspector General published an audit of the city's 311 service-request process, a system receiving approximately 2.2 million to 2.3 million requests annually. The audit identified deficiencies in communication, status reporting, and the handling of duplicate requests, including inconsistencies in how departments identified and resolved overlapping reports. The findings did not demonstrate a widespread campaign of malicious reporting, and it would be improper to present them as evidence that residents were systematically using the platform to harass others. They did reveal operational weaknesses in a major municipal system responsible for translating public allegations into government work. Where an institution cannot reliably connect repeated requests to earlier determinations, it may struggle both to prevent unnecessary duplication and to recognize when a legitimate concern remains unresolved.

Fragmented jurisdiction creates a related difficulty. A single property condition may implicate zoning, building safety, drainage, transportation, or public-right-of-way requirements, each administered by a different department or governmental body. Separate agencies may have independent reasons to examine the same physical condition, and the existence of overlapping investigations does not make them improper. Yet the cumulative burden on the recipient may be considerable, particularly when the agencies maintain separate records, issue different instructions, or lack a procedure for coordinating their findings. A complainant seeking to maximize procedural pressure might attempt to exploit those divisions by directing related allegations to several authorities. Whether that conduct constitutes legally actionable abuse would depend on the facts and applicable law, but the administrative vulnerability does not depend on proving a malicious complainant. It arises whenever government lacks a sufficiently coherent account of the demands its separate departments are imposing on the same person.

These weaknesses raise a question about the relationship between private influence and public authority. In City of Columbia v. Omni Outdoor Advertising, Inc. (1991), the Supreme Court examined an antitrust dispute involving billboard regulation in Columbia, South Carolina. An established billboard company had supported zoning restrictions that disadvantaged a competitor, which alleged an anticompetitive arrangement between the incumbent and municipal officials. The Court held that the challenged governmental action was protected by state-action antitrust immunity and that the private petitioning was protected under Noerr-Pennington principles. It rejected the proposed exception based on allegations of conspiracy between the municipality and the private company. The decision demonstrates the legal importance of distinguishing a private party's effort to obtain favorable regulation from conduct that violates an independent legal prohibition. Government decisions frequently benefit some interests and disadvantage others, and the existence of that disparity does not, without more, establish unlawful influence.

The concept of regulatory capture describes a more systemic distortion, in which public institutions become responsive to concentrated private interests at the expense of the broader purposes they are meant to serve. It should not be applied casually to an ordinary complaint, even one submitted by a persistent or influential resident. A meaningful inquiry would require evidence concerning the institution's behavior: whether similarly situated allegations receive comparable treatment, whether established procedures are applied consistently, whether enforcement priorities reflect independently assessed risks, and whether particular individuals obtain departures from ordinary practice. The Kansas City findings suggest that unequal administrative attention can arise without deliberate favoritism, because the information entering the system is itself unevenly distributed. That possibility becomes more consequential when complaint records are used to inform automated prioritization or predictive models. Technology can process information efficiently without establishing whether the information accurately represents the conditions government is supposed to regulate.

The law provides important but incomplete answers to these institutional questions. The First Amendment protects petitioning, and American courts have repeatedly resisted efforts to impose liability on people merely for pursuing unsuccessful or antagonistic proceedings. Yet constitutional protection is not absolute. In McDonald v. Smith (1985), the Supreme Court held that the Petition Clause does not confer absolute immunity from defamation liability for allegedly defamatory statements submitted to government officials. The decision concerned communications about a prospective federal appointee, not a municipal code complaint, and it did not eliminate the privileges, fault requirements, or other elements governing defamation claims. Its significance is narrower and more precise: the constitutional right to petition does not automatically place every statement made to government beyond civil accountability.

The distinction between protected petitioning and actionable misuse is equally important in state tort law. In Badell v. Beeks (1988), the Idaho Supreme Court considered claims of malicious prosecution and abuse of process arising from unsuccessful civil litigation. The court reaffirmed that abuse of process requires more than an improper motive; it involves a willful misuse of process in a manner not proper to the regular conduct of the proceeding. The court concluded that the evidence did not establish such misuse. The case illustrates why describing a complaint as retaliatory or malicious does not necessarily identify a viable legal remedy. The claimant must establish the elements of a recognized cause of action, and an informal administrative report may not constitute the kind of legal process contemplated by the traditional tort.

In Berian v. Berberian (2020), the Idaho Supreme Court addressed malicious-prosecution claims arising from criminal accusations and arrests following a family property dispute. The court concluded that factual questions concerning probable cause prevented summary judgment on those claims. That decision demonstrates that allegedly improper reporting can produce civil liability questions when the relevant legal elements are present. It does not establish that a disputed zoning complaint should be treated in the same manner as the initiation of criminal proceedings. The differences among an administrative inquiry, a civil lawsuit, and a criminal prosecution are legally consequential, particularly when evaluating probable cause, favorable termination, the use of judicial process, and applicable immunities.

These limitations can leave a substantial distance between a person's experience of an investigation and the remedies available under law. An allegation may have been submitted out of hostility without satisfying the requirements for abuse of process. An investigation may impose costs without violating due process. A complainant may be acting improperly while the agency correctly identifies a genuine violation, just as a complainant may act responsibly while officials make an unreasonable or legally mistaken demand. The conduct of the private individual and the conduct of the government must be evaluated independently. Once an agency elects to investigate, interpret an ordinance, request evidence, or pursue enforcement, it exercises its own authority. The legal legitimacy of that exercise cannot be determined solely by examining the motives of the person who requested it.

This distinction returns the inquiry to institutional design. The Organisation for Economic Co-operation and Development's Regulatory Enforcement and Inspections Toolkit (2018) recommends risk-based, evidence-informed, proportionate enforcement, including the careful assessment of complaints rather than automatic reliance on their submission as a sufficient reason for identical investigative responses. The framework recognizes that government cannot devote unlimited resources to every possible infraction and that the seriousness of the alleged harm should influence how regulatory attention is allocated. Its relevance to administrative weaponization is substantial, although it does not establish that any particular municipality is failing to follow these principles. A report concerning an imminent structural danger may warrant urgent investigation despite incomplete evidence. A low-risk allegation concerning a longstanding condition may permit preliminary examination of existing records before the agency requires extensive documentation from the property owner. The appropriate decision depends on the governing law, the evidence available, and the nature of the alleged risk.

Comparative administrative guidance provides another perspective. The United Kingdom's Local Government and Social Care Ombudsman has published guidance on managing unreasonable actions by complainants, recognizing that persistent or excessive conduct can interfere with an organization's ability to provide services. The guidance also cautions against treating persistence itself as evidence of wrongdoing, since repeated complaints may reflect a legitimate unresolved concern. Its recommended responses emphasize documentation, proportionality, and individualized assessment rather than blanket restrictions. American municipalities operate under different constitutional and statutory obligations, and such guidance cannot simply be adopted as a substitute for domestic law. It nevertheless demonstrates that public institutions can distinguish the protection of complaint rights from an obligation to process every repetition without regard to previous findings or available evidence.

The practical reforms suggested by this research are not particularly dramatic, but their significance lies in making administrative judgment visible and reviewable. A coherent complaint record should identify the underlying condition, earlier allegations, prior findings, and any materially new evidence. Officials should be able to distinguish independently corroborated reports from repeated submissions of the same assertion. Agencies with overlapping jurisdiction should coordinate where the law permits, particularly when separate inquiries concern substantially identical facts. Investigative demands should be proportionate to the seriousness of the alleged condition and the information reasonably necessary to establish compliance. Individuals subject to enforcement should receive intelligible explanations of the governing requirements, the factual basis for adverse determinations, and the procedures available to contest errors. None of these safeguards eliminates the possibility of an unfounded investigation, nor should it. Their purpose is to reduce avoidable burdens without compromising the government's capacity to investigate genuine problems.

Such reforms also require caution. Anonymous reporting may be necessary to protect people who fear retaliation. A heightened evidentiary threshold could make it difficult to report hazards that residents cannot document without official assistance. Restrictions on repeated complaints could conceal failures by agencies that have previously closed matters without adequate investigation. A policy intended to prevent administrative harassment could itself become a means of suppressing inconvenient complainants. The central requirement is therefore not a rigid rule against persistence, anonymity, or repeated reporting, but an institution capable of explaining why a particular allegation warrants action and why the response selected is appropriate to the evidence and the risk.

The experience of municipal enforcement in places such as Boise, Idaho, makes the distinction between authority and judgment particularly important. Boise City Code § 11-05-07 establishes mechanisms for investigating and addressing zoning violations, including authorized enforcement measures. The existence of those powers does not establish that every citizen report must generate an inspection or that every repeated allegation requires a new proceeding. Nor does it establish whether the city has adequate internal procedures for recognizing duplication, coordinating departments, or reviewing contested enforcement decisions. Those are questions about actual administrative practice, to be answered through governing policies, records, and documented decisions rather than assumptions drawn from the text of the ordinance. A government may possess lawful authority to investigate a condition while retaining meaningful discretion concerning how the investigation is conducted and what demands are reasonably necessary.

The distinction has implications for legal accountability. An appeal from a final citation may correct an erroneous interpretation of an ordinance, but it may not address the expense incurred in establishing that the citation should never have been issued. An agency may withdraw a notice after reviewing evidence that could have been obtained earlier. A person may comply with a demand because the cost of contesting it exceeds the cost of compliance, even when the legal basis for the demand is uncertain. These possibilities do not establish that enforcement systems routinely operate coercively. They do demonstrate why measuring administrative performance solely by the number of complaints resolved or violations corrected provides an incomplete picture of what the institution has required of the people subject to its authority.

The evidence available from judicial decisions, administrative scholarship, municipal audits, and studies of resident reporting supports a careful conclusion. Government procedures can impose substantial costs before the merits of an allegation have been resolved. Complaint-driven systems can reflect unequal reporting behavior rather than the underlying distribution of public risk. Repeated and overlapping allegations can create operational difficulties, particularly where records and responsibilities are fragmented. American law strongly protects legitimate petitioning and recognizes certain forms of procedural abuse, but the remedies available for disputed administrative complaints are limited and highly dependent on context. What the evidence does not establish is a reliable national prevalence rate for deliberate municipal complaint harassment, or a basis for assuming that most complainants who impose costs on others are acting in bad faith. The institutional concern is supported more clearly than any claim about how frequently individuals exploit it.

That distinction is indispensable to a credible account of administrative power. The strongest argument for reform does not require treating the complainant as a presumptive wrongdoer or the government as a passive instrument of private hostility. It begins with the recognition that the decision to investigate belongs to the institution exercising public authority, and that the consequences of that decision deserve scrutiny even when the original allegation came from a private citizen. The right to request governmental intervention must remain meaningful, particularly for people who lack other means of securing attention to genuine hazards or unlawful conduct. But the existence of that right does not relieve officials of responsibility for assessing evidence, recognizing prior determinations, coordinating overlapping proceedings, and avoiding demands disproportionate to the legitimate purpose of enforcement.

The machinery of a complaint is ultimately a system for converting private information into public action. Its legitimacy depends not only on the openness of the channel through which allegations enter, but on the quality of the judgment exercised after they arrive. Where an institution can distinguish reporting from proof, persistence from corroboration, and lawful investigative authority from unnecessary procedural burden, it can preserve the public's right to seek enforcement without allowing the process itself to become an unexamined sanction. Where those distinctions disappear, the costs of investigation may be distributed according to who is accused, who complains, and how efficiently the machinery responds, rather than according to what the law and the evidence actually require. The question is not whether government should be accessible to those who seek its intervention. It is whether the government remains sufficiently independent, disciplined, and accountable once that intervention has been requested.

References

Badell v. Beeks, 115 Idaho 101, 765 P.2d 126 (1988). https://law.justia.com/cases/idaho/supreme-court/1988/115-idaho-101.html

BE&K Construction Co. v. National Labor Relations Board, 536 U.S. 516 (2002). https://supreme.justia.com/cases/federal/us/536/516/

Berian v. Berberian, Idaho Supreme Court, No. 47122 (2020). https://law.justia.com/cases/idaho/supreme-court-civil/2020/47122.html

Boise City Code § 11-05-07. Violations, enforcement, and penalties. American Legal Publishing. https://codelibrary.amlegal.com/codes/boise_id/latest/boise/0-0-0-70163

California Motor Transport Co. v. Trucking Unlimited, 404 U.S. 508 (1972). https://www.law.cornell.edu/supremecourt/text/404/508

Chicago Office of Inspector General. (2026, February 26). Audit of 311 service request process. https://igchicago.org/publications/311-service-request-audit/

City of Columbia v. Omni Outdoor Advertising, Inc., 499 U.S. 365 (1991). https://www.law.cornell.edu/supremecourt/text/499/365

Kontokosta, C. E., & Hong, B. (2021). Bias in smart city governance: How socio-spatial disparities in 311 complaint behavior impact the fairness of data-driven decisions. Sustainable Cities and Society, 64, Article 102503. https://doi.org/10.1016/j.scs.2020.102503

Local Government and Social Care Ombudsman. (2024). Managing unreasonable actions by complainants: A guide for organisations. https://www.lgo.org.uk/information-centre/information-for-organisations-we-investigate/councils/good-practice-guides/managing-unreasonable-actions-by-complainants-a-guide-for-organisations

McDonald v. Smith, 472 U.S. 479 (1985). https://www.law.cornell.edu/supremecourt/text/472/479

Moynihan, D., Herd, P., & Harvey, H. (2015). Administrative burden: Learning, psychological, and compliance costs in citizen-state interactions. Journal of Public Administration Research and Theory, 25(1), 43–69. https://doi.org/10.1093/jopart/muu009

Organisation for Economic Co-operation and Development. (2018). OECD regulatory enforcement and inspections toolkit. OECD Publishing. https://doi.org/10.1787/9789264303959-en

Professional Real Estate Investors, Inc. v. Columbia Pictures Industries, Inc., 508 U.S. 49 (1993). https://www.law.cornell.edu/supremecourt/text/508/49

Thompson v. Village of Monee, No. 1:23-cv-13982, Document 270 (N.D. Ill. May 28, 2026). https://law.justia.com/cases/federal/district-courts/illinois/ilndce/1:2023cv13982/445669/270/