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Text of the "But For" Test as interpreted by Illinois Appellate Court

(40 posts)
  1. Catherine
    Member

    OK, I am not a lawyer, but I hope that citizens can read and understand (at least as through a glass, darkly) the law they pay for, although they certainly cannot give legal advice! Do you think we pass this test as discussed by one of our appellate courts in the Pleasantdale decision. I mean, doesn't this sound just like us? This is but one test which must be passed in order to qualify. I thought I would just post it here for those unable or unwilling to dig it up!

    "II. But-For Finding

    The trial court also found that development of the Subject Property would occur without the aid of TIF designation. The TIF Act requires a showing that the Subject Property "would not reasonably be anticipated to be developed without the adoption of the redevelopment plan." 65 ILCS 5/11-74.4-3(n)(J)(1) (West 2002). This is the but-for test.

    The Village contends that the trial court's but-for finding was in error because the court failed to consider that the development of property within the proposed TIF district has been stagnated while properties outside the TIF area have continued to develop. The Village is incorrect. An examination of the trial court's order granting the School District's motion for summary judgment shows that the court was aware that economic development in the proposed TIF district had been stagnated. The trial court, however, determined that this stagnation was not attributable to any alleged blighting factors on the Subject Property but, rather, was due to the tax disparities between Cook and DuPage Counties. The trial court also noted that, in spite of the large tax impediment, a 30-screen movie complex and a residential townhome development had been proposed for the Subject Property but were denied by the Village planning commission after a large number of residents actively campaigned against the two projects.
    The record shows that the absence of TIF financing did not discourage other developers from being interested in the Subject Property. For example, a company called Care Matrix was willing to proceed with a development on 19 acres of the Subject Property without TIF financing. Moreover, the course of development in the area immediately surrounding the Subject Property supports the trial court's finding that the lack of development on the Subject Property is due to the tax disparities between Cook and DuPage Counties rather than any statutory blighting factors. The record shows that during the early to mid 1990s, three banks, two office buildings and a restaurant were developed in the immediate area of the Subject Property. The record also shows that Barton proceeded with his project before the Village actually adopted the ordinances establishing the TIF district.

    Given the evidence showing that developers were interested in the Subject Property without TIF financing and the evidence that growth and development were occurring in the immediate area of the Subject Property, there is no basis in the record to overturn the trial court's finding that the Village failed to meet the but-for test articulated in the TIF Act. See Castel Properties, 259 Ill. App. 3d at 442-43 (affirming the trial court's finding that the city therein failed to meet the but-for test, highlighting the extensive evidence of growth and redevelopment occurring in the area and noting that a project was being developed without the TIF issue having been determined)."

    Of particular interest to me was that the failure to develop had to be "due to the blighting factors" and not merely accompanying any blighting factors. (Leaving apart any argument of whether a sufficient number of blighting elements are present to qualify us.) And also that development NEAR the TIF area was disqualifying.

    Posted Thursday Mar 1, 2007 16:50 #
  2. Aberdeen
    Member

    Catherine: Thank you for posting this important language. I've had this 1st District case Shepardized and it is still good law.

    Looking at the map of the proposed TIF area, the manner in which it cuts so close around the VC may be problematic for the Village.

    Posted Friday Mar 2, 2007 09:57 #
  3. spatny
    Member

    Exactly. And if they redraw this to include Woodside and the schools it will really be bizarre. Plus add in a whole lot of single family homes. Some of the SW side of Woodside lots go through to Kimbark. Would that have any effect?

    Posted Friday Mar 2, 2007 11:02 #
  4. Tim
    Member

    One possible negative effect of extending the TIF to include Woodside and the schools is the inclusion of even more residential EAV into the TIF District.

    This could potentially place a greater strain on all other taxing bodies as more naturally occurring growth within the residential sector is going to be captured for the TIF FUND that would have otherwise gone to all taxing bodies.

    Posted Friday Mar 2, 2007 14:33 #
  5. Aberdeen
    Member

    Don - all such cases are argued on their own unique facts. I don't think anyone wants to even imagine Riverside going into litigation over this, though. After all, we are all neighbors at the end of the day. And I think our Trustees are recognizing that there are material issues that need to be addressed.

    Posted Friday Mar 2, 2007 14:35 #
  6. spatny
    Member

    Aberdeen - I wasn't advocating any litigation. I don't like dealing with lawyers - except you, of course. I just meant that I heard something about having to include property on both sides of a street, not just one side, and if the Woodside properties extend to Kimbark, then what? It was just a question.

    Posted Friday Mar 2, 2007 14:58 #
  7. Catherine
    Member

    No, I would hope that the many attorneys on the Board and the village government's attorney would have closely considered the relevance of these cases so as to render litigation useless, rather than to rely on the opinion of the consultants. That is my aim in bringing it up. I am genuinely of the personal opinion that TIF is a tool much abused from its original purpose. I don't really think our facts are so unique as to distinguish them from these opinions. Pleasantdale cites two other cases as well:

    Henry County v. Village of Orion
    278 Ill. App. 3d 1058, 663 N.E. 2d 1076 (1996 3d Dist.)
    Found failure of “but for— and found new building already occurring within a proposed TIF area. That is also our situation here.

    Castel Property v. City of Marion
    259 Ill. App. 3d 432, 631 N.E. 2d 459 (1994 5th Dist.)
    Found failure of but for because growth and development was occurring in the direction of the redevelopment area, in proximity to the redevelopment area before adoption of a final TIF. This, again, is our situation here.

    I am glad to read that one of the persons standing for trustee is questioning whether we qualify for a TIF.

    Posted Friday Mar 2, 2007 17:13 #
  8. Lonnie
    Member

    If the village insists on this TIF in the face of the amount of controversy and opposition it has aroused, then I think litigation, as distasteful as it may be, should not be ruled out. I firmly agree that the original intent of the TIF law has been significantly abused. It's time to properly construe the "but for" test without spurious arguments. In Riverside the need for a TIF simply comes down to whether or not you see development occurring in and around the district. I think the answer is staring us in the face.

    Posted Friday Mar 2, 2007 18:23 #
  9. MikeT
    Member

    Lonnie and Spatny:

    The TIF is getting bigger, and Lonnie is getting larger.+

    It's now* on Woodside and staring you in your face.

    .
    .
    +with apologies to Airplane, and to MikeS and JDougPollock for being way too silly

    *in concept

    I must have flippettes, a condition like Tourettes, where a joke, no matter how stupid and cheap is said, regardless of the seriousness of the circumstances.

    Posted Friday Mar 2, 2007 18:56 #
  10. spatny
    Member

    Mike - you're a gem. Keep confounding the opposition. Bring that TIF up here and we'll eat it for breakfast, I just had a conversation today with a very savvy labor lawyer, and was told that there are many, many of these things in the works that are going to boomerang on those that are passing them, because down the road they are being discovered invalid or misapplied. Anyway, why do we need it? No one can answer that except to say expenses are larger than income. Well that's not a phenomenon that people don't understand. Cut back. Use your heads for something besides a hat rack. Get creative. Why, when you have something so unique, strive to be so mundane. Small minds are ever so.

    Posted Friday Mar 2, 2007 20:02 #

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