Parvati Corp. v. City of Oak Forest, 709 F.3d 678

Parvati owned a Ramada Inn in Oak Forest in an M zone; hotel failed commercially and Parvati sought to sell for retirement use mainly for black residents.
City officials discussed converting the hotel to a retirement home; meeting suggested officials favored the idea but testimony uncertain.
City amended the zoning to split M into M-1 and M-2, removing highway-oriented and residential uses; hotel became nonconforming.
Parvati arranged a sale contingent on zoning change; the church-linked buyer would house mostly black residents, raising race-based concerns.
The city later denied a special-use permit for the retirement-home plan; Parvati foreclosed, and the hotel currently operates as a highway-oriented hotel under different branding.
Parvati claimed racial discrimination and a vague ordinance; the district court granted summary judgment for the City; on appeal, the court analyzed discrimination claims and vagueness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prima facie racial-discrimination claim under §1981/1982	Parvati argues irregular zoning actions reflect racial targeting via church buyer.	City asserts no proof of race-based discriminatory intent; no strong evidence of intent.	Parvati failed to prove a prima facie case of racial discrimination.
Irregularities in zoning process amounting to discrimination	Patterns in rezoning indicate discrimination against sale to black church buyer.	Irregularities are routine zoning issues, not evidence of racial bias.	Irregularities alone insufficient to prove discrimination; no disparate impact evidence.
Vagueness of zoning ordinance	Omission and later amendments caused uncertainty about permissible uses.	Amendments were corrected; no harm shown from the glitch; vagueness not actionable for damages.	Vagueness existed briefly but was rectified; no damages linked to the vagueness.
Damages under new-business rule	Damages should reflect lost sale value due to discriminatory zoning.	New-business rule bars damages for losses to a new business.	Rule reversed inapplicable here; but discrimination not proven; damages not awarded.
Damages measure and availability	Damages equal to difference between hotel value and sale price ($4.5M).	Damage proof insufficient without proven discriminatory causation.	Damages not awarded; no proven discriminatory causation.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (prima facie case framework for discrimination claims)
Grayned v. City of Rockford, 408 U.S. 104 (1972) (vagueness concerns in anti-discrimination regulations)
Sullivan v. Little Hunting Park, Inc., 396 U.S. 229 (1969) (standing of a business to challenge discriminatory actions against customers)
New West, L.P. v. City of Joliet, 491 F.3d 717 (7th Cir. 2007) (context for ancillary damages and discrimination analysis)
MindGames, Inc. v. Western Publishing Co., 218 F.3d 652 (7th Cir. 2000) (discredited new-business rule as bar to damages in some settings)