Subject-matter Jurisdiction

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7^th Circuit Court of Appeals

Case Name: Protect our Parks, Inc., et al., v. Chicago Park District, et al.,

Case No.: 19-2308; 19-3333

Officials: MANION, BARRETT, and BRENNAN, Circuit Judges.

Focus: Subject-matter Jurisdiction

This case is about the plaintiffs’ quest to halt construction of the Obama Presidential Center in Chicago’s Jackson Park. First developed as the site for the Chicago World’s Fair in 1893, Jackson Park has a storied place in Chicago history, and as public land, it must remain dedicated to a public purpose. The City made the judgment that hosting a center devoted to the achievements of America’s first African-American President, who has a longstanding connection to Chicago, fit that bill. Vehemently disagreeing, the plaintiffs sued the City of Chicago and the Chicago Park District to stop the project. They brought a host of federal and state claims, all asserting variants of the theory that the Obama Presidential Center does not serve the public interest but rather the private interest of its sponsor, the Barack Obama Foundation.

The district court granted summary judgment to the defendants across the board, and the plaintiffs appeal. We affirm the district court’s judgment as to the federal claims, but we hold that it should have dismissed the state claims for lack of jurisdiction. Federal courts are only permitted to adjudicate claims that have allegedly caused the plaintiff a concrete injury; a plaintiff cannot come to federal court simply to air a generalized policy grievance. The federal claims allege a concrete injury, albeit one that, as it turns out, the law does not recognize. The state claims, however, allege only policy disagreements with Chicago and the Park District, so neither we nor the district court has jurisdiction to decide them.

Affirmed and vacated in part. Cause remanded

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Derek A Hawkins is trademark corporate counsel for Harley-Davidson. Hawkins oversees the prosecution and maintenance of the Harley-Davidson’s international trademark portfolio in emerging markets.