## Facts

- Soldier Field is located in Burnham Park on Chicago’s lakefront on land that was formerly part of Lake Michigan but has long been filled and used as parkland.
- Since opening in 1924, the stadium has hosted a wide range of public events; since 1971 it has also served as the Chicago Bears’ home field under agreements with the Chicago Park District.
- In 2001, the Illinois General Assembly amended the Illinois Sports Facilities Authority Act to authorize the Illinois Sports Facilities Authority to finance physical improvements to Burnham Park, including renovation and expansion of Soldier Field, using public financing mechanisms.
- The statute included legislative findings that the project served public purposes, including improving facilities for public events and supporting tourism and economic activity.
- Friends of the Parks, individual members, and a preservation organization sued the Park District, the Authority, the Bears, a stadium entity, and the City of Chicago, seeking declaratory relief that the authorizing legislation was unconstitutional.
- Plaintiffs alleged the project chiefly benefited a private professional football franchise, improperly used public funds and land, violated the public trust applicable to lakefront lands, and was enacted without complying with Illinois’s three-readings constitutional requirement.
- The circuit court dismissed most counts and later granted summary judgment for defendants; plaintiffs appealed, and the Illinois Supreme Court took direct review limited to the three constitutional questions.

## Issues

1. Whether authorizing public financing and use of public property for Soldier Field renovations violated the Illinois Constitution’s restriction that public funds, property, or credit be used only for public purposes.
2. Whether the authorization violated the public trust doctrine applicable to formerly submerged lakefront lands by subordinating public interests to a private franchise.
3. Whether the legislation was enacted in violation of the Illinois Constitution’s three-readings requirement.

## Decision

- The Illinois Supreme Court affirmed the circuit court’s judgment for defendants.
- The court held the legislation did not violate the public-purpose limitation because its primary objective was public and any private benefits to the Bears were incidental.
- The court held the legislation did not violate the public trust doctrine because public ownership and control were retained and the use remained consistent with park and recreational purposes.
- The court held the legislation complied with the three-readings requirement; legislative journals were treated as conclusive and supported compliance.

## Legal Principles

- A legislative determination that an expenditure serves a public purpose receives substantial deference; a statute is not invalid merely because private parties receive incidental benefits when the primary purpose is public.
- Public trust lands may be improved and used for public recreation and civic purposes so long as the government does not abdicate control or authorize a primarily private use that substantially impairs the public’s interests in the trust property.
- Courts presume regularity in legislative procedure; official legislative journals are conclusive evidence of compliance with the Illinois Constitution’s three-readings requirement absent a clear showing to the contrary.

## Conclusion

The Illinois Supreme Court upheld statutory authorization for publicly financed renovation and expansion of Soldier Field, concluding the project served a primarily public purpose, preserved public trust obligations through continued public ownership and recreational use, and was enacted in compliance with constitutional legislative procedure requirements.


Friends of the Parks v. Chi. Park Dist., 203 Ill. 2d 312, 786 N.E.2d 161 (Ill. 2003)