Illinois Supreme Court
Habdab, LLC v. County of Lake
November 21, 20242024 IL 130323
Summary
The court affirmed summary judgment for the County, holding that fees required by voluntary annexation agreements were not road improvement impact fees governed by the Impact Fee Law because they were imposed as a condition of annexation rather than as a condition of issuing a building permit or certificate of occupancy. The court also held that the fees did not violate the unconstitutional conditions doctrine because they had an essential nexus to reducing traffic congestion and were roughly proportional to the development's anticipated impact. No separate opinions were filed.