## Facts

- Illinois amended its Environmental Protection Act to subject certain nighttime professional sporting events to the Pollution Control Board’s nighttime noise-emission regulations.
- The amendment applied to nighttime baseball, football, and soccer events in cities over one million people at stadiums that had not hosted nighttime events before July 1, 1982.
- Chicago enacted an ordinance prohibiting athletic contests between 8:00 p.m. and 8:00 a.m. at stadiums that were not totally enclosed, had more than 15,000 seats, and were within 500 feet of 100 or more dwelling units.
- The parties agreed the ordinance would prohibit night games at Wrigley Field, a large, open-air stadium in a densely residential neighborhood.
- The Chicago National League Ball Club (Chicago Cubs/Wrigley Field operator) sought declaratory and injunctive relief, alleging the statute and ordinance violated separation of powers, due process, equal protection, and the Illinois Constitution’s special-legislation clause.
- The circuit court granted judgment on the pleadings for defendants and an intervening neighborhood group, holding the measures were reasonable exercises of the police power; the club appealed directly to the Illinois Supreme Court.

## Issues

1. Whether the state amendment and city ordinance constituted unconstitutional special legislation by effectively targeting Wrigley Field.
2. Whether the measures’ classifications violated equal protection under rational-basis review.
3. Whether the measures violated substantive due process by unreasonably restricting the club’s property use and business operations.
4. Whether the statutory scheme violated separation-of-powers principles through improper delegation to or use of administrative authority.

## Decision

- The Illinois Supreme Court affirmed the judgment upholding both the state amendment and the city ordinance.
- The Court held the measures were reasonable exercises of the police power aimed at nighttime noise and neighborhood impacts.
- The Court rejected special-legislation, equal-protection, due-process, and separation-of-powers challenges.

## Legal Principles

- Noise abatement and protection of residential communities from nighttime disruptions are legitimate governmental objectives supporting regulation under the police power.
- Under rational-basis review, legislative classifications are upheld if any reasonably conceivable facts could justify a rational relationship between the classification and the governmental purpose.
- A law is not unconstitutional special legislation merely because it affects a small number of entities; if it uses general criteria rationally related to legitimate aims and does not create an arbitrary closed class, it may be upheld.
- Delegation to an administrative body to apply and enforce regulatory standards (such as noise emission limits) does not violate separation of powers when consistent with ordinary administrative implementation of legislative policy.
- Substantive due process permits significant regulation of property use when the regulation is reasonably related to a legitimate public purpose and is not arbitrary.

## Conclusion

The Illinois Supreme Court sustained state and municipal restrictions that effectively barred night games at Wrigley Field, concluding that the measures were rationally related to legitimate interests in nighttime noise control and neighborhood welfare and did not violate special-legislation, equal-protection, due-process, or separation-of-powers limits.


Chi. Nat'l League Ball Club, Inc. v. Thompson, 108 Ill. 2d 357, 483 N.E.2d 1245 (Ill. 1985)