Chicago Joe's Tea Room, LLC v. Village of Broadview, No. 22-3194 (7th Cir. 2024)
Annotate this CaseIn this case, the plaintiff, Chicago Joe's Tea Room LLC, had plans to open an adult entertainment business in a suburb of Chicago. However, the Village of Broadview denied the plaintiff's application for a special-use permit, which led to the plaintiff claiming that their constitutional rights were violated. The plaintiff sought millions of dollars in lost profits for the business that never opened. The U.S. District Court for the Northern District of Illinois excluded most of the plaintiff's evidence and theories for lost-profit damages due to substantive and procedural issues. The court then awarded the plaintiff just $15,111 in damages. The plaintiff appealed, but the United States Court of Appeals for the Seventh Circuit affirmed the decision of the lower court, finding no abuses of discretion. The appellate court stated that the plaintiff's calculations of lost profits were beyond the scope of the plaintiff's personal knowledge of a similar business and required expert-like analysis and adjustments. The court also ruled that the plaintiff failed to disclose necessary damages evidence in a timely manner, a violation of the Federal Rules of Civil Procedure. The plaintiff was also denied the opportunity to amend their complaint to challenge a state statute, as the request was made a decade after the issue became relevant. The court found that granting the amendment would have caused undue delay and prejudice to the Village.
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