## Facts

- Landowners and a land trustee petitioned to disconnect approximately 95 acres from the Village of Barrington Hills under § 7-3-6 of the Illinois Municipal Code.
- The tract lay on the village’s western boundary in Kane County, shaped like an inverted “L,” bordered on three sides by the Village of Carpentersville.
- The property was largely separated from the rest of Barrington Hills by a forest preserve, leaving it geographically and functionally isolated from the village.
- Petitioners sought disconnection so the tract could be annexed to Carpentersville and developed at a higher density than allowed by Barrington Hills’ five-acre minimum lot zoning.
- Evidence indicated Carpentersville had water and sewer infrastructure near the tract and was willing to serve it; Barrington Hills did not provide comparable urban services.
- Expert testimony supported that the tract’s municipal and development relationship was more logical with Carpentersville and that detachment would not materially harm Barrington Hills’ growth.

## Issues

1. Whether disconnection of the 95-acre tract would “unreasonably disrupt the growth prospects and plan and zoning ordinances” of the Village of Barrington Hills under § 7-3-6, thereby barring disconnection.

## Decision

- The Illinois Supreme Court affirmed the appellate court.
- The court held petitioners proved the statutory requirements, including that disconnection would not unreasonably disrupt the village’s growth prospects or its planning and zoning ordinances.
- The court ordered that the disconnection petition be granted.

## Legal Principles

- Under § 7-3-6, petitioners bear the burden to prove each statutory element for disconnection; if proven, disconnection is mandatory rather than discretionary.
- The statute protects a municipality from unreasonable disruption of growth and internal planning, not from any loss of territory or every adverse consequence.
- Geographic isolation and functional orientation toward a neighboring municipality can support a finding that disconnection will not unreasonably disrupt the municipality’s growth and planning.
- A municipality cannot rely on the prospect of higher-density development in a neighboring jurisdiction to show unreasonable disruption; the statute protects zoning and planning within the municipality’s remaining borders.
- Speculative “floodgates” arguments about other potential future disconnection petitions are insufficient; the inquiry is case-specific.

## Conclusion

Because the tract was nearly surrounded by another municipality, separated from Barrington Hills by a forest preserve, and better served by Carpentersville’s infrastructure, the court concluded detachment would not unreasonably impair Barrington Hills’ growth prospects or its ability to maintain its low-density zoning scheme on the land that remained within the village.


Harris Tr. & Sav. Bank v. Vill. of Barrington Hills, 133 Ill. 2d 146, 549 N.E.2d 578 (Ill. 1989)