No. 20- IN THE SUPREME COURT OF THE UNITED STATES PROTECT OUR PARKS, INC. AND MARIA VALENCIA, Petitioners, v. THE CITY OF CHICAGO AND THE CHICAGO PARK DISTRICT, Respondents. On Petition for Writ of Certiorari to the United States Court of Appeals for the Seventh Circuit PETITION FOR WRIT OF CERTIORARI Richard A. Epstein 16 Thomas Place Norwalk, Connecticut 06853 773-450-4476
[email protected] Michael Rachlis Counsel of Record Rachlis Duff & Peel LLC 542 South Dearborn Street Suite 900 Chicago, Illinois 60605
[email protected] Counsel for Petitioners QUESTIONS PRESENTED The questions presented are: 1. Whether the Plaintiffs possess Article III standing to bring their takings and due process claims in light of the Seventh Circuit’s application of Lujan v. National Wildlife Federation, 497 U.S. 871 (1990) and similar authorities of this Court? 2. If standing exists, whether the City of Chicago violated Plaintiffs’ Fifth and Fourteenth Amendment rights on their takings and due process claims? i PARTIES TO THE PROCEEDING AND CORPORATE DISCLOSURE Petitioners are Protect Our Parks, Inc. and Maria Valencia. The Respondents are the City of Chicago and the Chicago Park District. Petitioner Protect Our Parks, Inc. is a non-profit corporation with no parent entities that does not issue stock. RELATED PROCEEDINGS Protect Our Parks, Inc. v. Chicago Park District, et al, No. 18-cv-03424, U.S. District Court for the Northern District of Illinois. Judgment entered June 11, 2019 (Motion for Summary Judgment) and November 6, 2019 (Rule 60 Motion). Protect Our Parks, Inc. v. Chicago Park District, et al, Nos.