Parvati Corp. v. City of Oak Forest, Ill., 2010 U.S. App. LEXIS 26092

Parvati Corporation owned a Ramada Inn in Oak Forest and agreed in 2004 to sell to Bethlehem contingent on Bethlehem obtaining city approval to operate as a senior-living facility.
In 2006 the City’s Zoning Commission denied Bethlehem’s license due to a newly enacted ordinance (Ordinance 2836) prohibiting that use.
Parvati and Bethlehem sued for judicial review and various claims; the case was removed to federal court, and in 2007 the district court affirmed the zoning denial and dismissed the administrative-review claim; remaining claims were voluntarily dismissed and judgment entered.
In early 2008 Parvati discovered alleged misrepresentations about Ordinance 2836 and moved for Rule 60(b)(3) relief; Bethlehem was no longer a party, and Parvati conveyed the property to Mutual Bank in a foreclosure-related agreement.
Parvati filed a new suit reasserting dismissed claims; the district court found standing based on potential preclusion effects, reaffirmed the prior judgment, and denied Rule 60(b)(3) and Rule 59(e) relief.
On appeal, the Seventh Circuit held the case moot and vacated and remanded to dismiss for lack of jurisdiction, finding Parvati lacked standing to reopen the administrative-review claim and that preclusion injuries were self-inflicted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Parvati has standing to seek Rule 60(b)(3)/Rule 59 relief	Parvati asserts standing via potential preclusion effects on related suit and continued monetary-claims relief.	City contends Parvati lacks standing because ownership transfer defeats the injury and preclusion issue is self-inflicted.	Parvati lacks standing; case moot; dismissal for lack of jurisdiction.

Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires injury that is concrete, particularized, and actual or imminent)
Allen v. Wright, 468 U.S. 737 (1984) (standing requires a causal link and redressability)
Friends of the Earth, Inc. v. Laidlaw Envtl. Servs. (TOC), Inc., 528 U.S. 167 (2000) (standing must be present for each form of relief sought)
Provident Sav. Bank v. Popovich, 71 F.3d 696 (7th Cir. 1995) (Rule 60(b) cannot be used to raise new legal theories raised earlier)
Petro-Chem Processing, Inc. v. EPA, 866 F.2d 433 (D.C. Cir. 1989) (self-inflicted injuries break the causal chain for standing)
Highway J Citizens Group v. U.S. Dep't of Transp., 456 F.3d 734 (7th Cir. 2006) (collateral estoppel/preclusion considerations in standing)
Muhammad v. Oliver, 547 F.3d 874 (7th Cir. 2008) (voluntary dismissal of claims does not preserve rights or avoid preclusion)