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Administrative Law Keyed to Popper
Black v. Village of Park Forest
Citation:
20 F. Supp. 2d 1218 (1998)Facts
In 1994, the Village of Park Forest amended its Housing Code to authorize annual inspections of rental properties. The program specifically targeted rented single-family homes, subjecting them to interior inspections, while other types of properties (including multi-family dwellings) were subject only to exterior and common area inspections. When scheduling inspections, the Village would contact landlords rather than tenants. If either a landlord or tenant objected to an inspection, the Village would obtain an administrative search warrant and charge the landlord an additional $60 fee. The plaintiffs, who were tenants in single-family rental homes, objected to these inspections, arguing they violated their Fourth Amendment rights. In one instance, when plaintiff Taylor was not present for a scheduled inspection, the Village attempted to hold her in contempt of court for failing to comply with the warrant. The Jabroskys initially objected to an inspection but later allowed their home to be inspected.
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