## Facts

- Coniston Corporation owned several hundred acres annexed into the Village of Hoffman Estates, Illinois, under an annexation agreement incorporating the Village’s land-use ordinances.
- The ordinances required (1) approval of a general development plan by the Village Board and (2) later approval of specific site plans for individual parcels, with Plan Commission review followed by Board action.
- Coniston obtained approval of the general plan.
- For a 17-acre parcel, Coniston submitted a site plan proposing five single-story commercial office buildings totaling about 181,000 square feet.
- The Plan Commission recommended approval, finding the site plan conformed to the general plan and applicable regulations.
- The Village Board of Trustees disapproved the site plan without issuing formal reasons; a trustee referenced concern about substantial unused office space in the Village.
- After reconsideration, including deliberations in executive session, the Board reaffirmed the denial without explanation.
- Coniston sued under 42 U.S.C. § 1983 alleging substantive and procedural due process violations (and related state-law theories).
- The district court dismissed under Rule 12(b)(6), and Coniston appealed.

## Issues

1. Whether denial of the site plan was so arbitrary or irrational as to violate substantive due process under the Fourteenth Amendment.
2. Whether the Board’s unreasoned denial (despite a favorable Plan Commission recommendation and executive-session deliberations) deprived Coniston of procedural due process.
3. Whether the Board’s action on the site plan was legislative rather than adjudicative, and how that classification affects procedural due process requirements.

## Decision

- The Seventh Circuit affirmed dismissal for failure to state a claim.
- The complaint did not plausibly allege a substantive due process violation because the denial could be explained by legitimate public-welfare concerns, including perceived office-space oversupply.
- No procedural due process violation was stated because the Board’s decision was treated as legislative in character, and legislative actions are not constitutionally required to include trial-type procedures or written reasons.

## Legal Principles

- Federal substantive due process review of local land-use decisions is narrow; a plaintiff must allege action so arbitrary that it lacks any conceivable legitimate governmental purpose.
- A municipal legislative body may reject a recommended site plan for policy reasons even when the proposal satisfies technical or regulatory criteria identified by a planning commission.
- When a challenged land-use decision is legislative in character, procedural due process does not require evidentiary hearings, formal findings, or written explanations; political accountability is the principal check.
- Section 1983 is not a vehicle for converting ordinary land-use disputes into federal constitutional claims absent extreme arbitrariness or comparable misconduct.

## Conclusion

The Seventh Circuit held that the Village Board’s denial of Coniston’s site plan—motivated by policy concerns such as office-space saturation and treated as legislative action—did not state a federal substantive or procedural due process claim under § 1983, so dismissal was proper.


Coniston Corp. v. Village of Hoffman Estates, 844 F.2d 461 (7th Cir. 1988)