BBLI Edison, LLC v. City of Chicago
CourtCourt of Appeals for the Seventh Circuit
Date FiledJuly 22, 2026
Docket25-1713
JudgeScudder
StatusPublished
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Full Opinion
In the
United States Court of Appeals
For the Seventh Circuit
____________________
No. 25-1713
BBLI EDISON, LLC, a Delaware limited liability company,
Plaintiff-Appellant,
v.
CITY OF CHICAGO, Department of Housing,
Defendant-Appellee.
____________________
Appeal from the United States District Court for
the Northern District of Illinois, Eastern Division.
No. 1:24-cv-04925 — Mary M. Rowland, Judge.
____________________
ARGUED NOVEMBER 14, 2025 — DECIDED JULY 22, 2026
____________________
Before SCUDDER, ST. EVE, and JACKSON-AKIWUMI, Circuit
Judges.
SCUDDER, Circuit Judge. A Chicago ordinance requires an-
yone who obtains a rental property through foreclosure to ne-
gotiate new leases with existing tenants in good faith. If a ten-
ant declines to renew a lease, the ordinance also requires the
landlord to pay the tenant $10,600 to assist with relocation ex-
penses. BBLI Edison contends that this amounts to an uncon-
2 No. 25-1713
stitutional taking. The district court disagreed and dismissed
the case. We affirm.
I
A
Chicago enacted the current version of the Keep Chicago
Renting Ordinance in 2021. Its stated purposes are “to protect
and promote the health, safety, and welfare of its residents”
and to “mitigate the damaging effects on our communities of
foreclosures ….” Chi., Ill. Mun. Code § 5-14-010. To effect
these purpose, the Ordinance requires new owners of rental
properties, acquired through foreclosure, to “negotiate[] in
good faith for a new rental agreement that lasts at least 12
months” with the existing tenants. Id. § 5-14-050(a)(1). If for
any reason a tenant does not sign a new lease, the new owner
must pay them a $10,600 relocation assistance fee. See id. The
payment appears to have no requirements, such as the tenant
committing to using the money to cover relocation costs. Nor,
does it seem, that the tenant must represent that they used the
payment to make a security deposit on a new apartment, to
cover moving costs, or the like. By its terms, the Ordinance
does not apply retroactively to owners who purchased their
buildings before its enactment. See id. § 5-14-030(a).
B
BBLI’s complaint supplies the pertinent facts. On Septem-
ber 23, 2022, BBLI’s unidentified predecessors-in-interest filed
a foreclosure action for a building at 5200 North Sheridan
Road in Chicago. BBLI took control of the property through a
sheriff’s deed dated February 9, 2024.
When BBLI took over the building, over 220 tenants re-
sided there. BBLI notified them of their rights under the Or-
No. 25-1713 3
dinance. At least five tenants have declined new leases and
requested that BBLI pay them the $10,600 relocation assis-
tance fee.
Invoking 42 U.S.C. § 1983, BBLI sued the City of Chicago
in federal court. It asked the district court to enjoin enforce-
ment of the Ordinance, alleging that it ran afoul of the Takings
Clause in various ways. The district court dismissed BBLI’s
complaint, finding no constitutional violation.
Declining an opportunity to amend its complaint, BBLI
now appeals.
II
A
“[N]or shall private property be taken for public use, with-
out just compensation.” U.S. CONST. amend. V; see also Sheetz
v. County of El Dorado, 601 U.S. 267, 276 (2024) (“[T]he Four-
teenth Amendment … incorporates the Takings Clause
against the States.”). Not to be mistaken for “a poor relation
among the provisions of the Bill of Rights,” many recent Su-
preme Court decisions illustrate the protection afforded by
the Takings Clause. Knick v. Township of Scott, 588 U.S. 180, 189
(2019) (cleaned up). We begin with an overview of the legal
landscape of physical takings, often referred to as “per se” tak-
ings in the case law.
Physical takings can occur whether “the government ac-
tion at issue comes garbed as a regulation (or statute, or ordi-
nance, or miscellaneous decree).” Cedar Point Nursery v. Has-
sid, 594 U.S. 139, 149 (2021). The “essential question” is
“whether the government has physically taken property for
itself or someone else—by whatever means.” Id.
4 No. 25-1713
The clearest forms of physical takings are “physical appro-
priations.” Id. at 148 (“The government commits a physical
taking when it uses its power of eminent domain to formally
condemn property.”). A lawful taking may occur in these sce-
narios so long as the government then honors its obligation to
justly compensate the former landowner. See Pung v. Isabella
County, 146 S. Ct. 1964, 1970–71 (2026) (discussing acceptable
ways to determine “just compensation” under the Takings
Clause).
Physical takings include more than just appropriations.
“[W]here government requires an owner to suffer a perma-
nent physical invasion of her property—however minor—it
must provide just compensation.” Lingle v. Chevron U.S.A.
Inc., 544 U.S. 528, 538 (2005) (citing Loretto v. Teleprompter
Manhattan CATV Corp., 458 U.S. 419 (1982)). They also extend
to forced temporary occupations. See Cedar Point Nursery, 594
U.S. at 162 (holding that an access right for union organizers
“constitutes a per se physical taking”).
The Takings Clause protects personal property too. See
Horne v. Dep’t of Agric., 576 U.S. 350, 361 (2015) (“The reserve
requirement imposed by the Raisin Committee is a clear phys-
ical taking” because “[a]ctual raisins are transferred from the
growers to the Government.”). And that personal property
can include cash. See Tyler v. Hennepin County, 598 U.S. 631,
642 (2023) (holding that following a forfeiture sale on a home
for unpaid taxes, the government may not retain “the surplus
in excess of the debt owed”).
But physical takings are not limitless. “[T]axes, user fees,
and similar laws and regulations that may impose financial
burdens on property owners” do not qualify as physical tak-
ings. Koontz v. St. Johns River Water Mgmt. Dist., 570 U.S. 595,
No. 25-1713 5
615 (2013). The government may also impose certain types of
requirements on the landlord-tenant relationship without
causing a physical taking. See Yee v. City of Escondido, 503 U.S.
519, 532 (1992) (“[The Escondido rent control ordinance] is a
regulation of petitioners’ use of their property, and thus does
not amount to a per se taking.”); see also Loretto, 458 U.S. at
440 (“This Court has consistently affirmed that States have
broad power to regulate housing conditions in general and
the landlord-tenant relationship in particular without paying
compensation for all economic injuries that such regulation
entails.”).
B
Chicago’s Ordinance first and foremost regulates the land-
lord-tenant relationship. And “statutes regulating the eco-
nomic relations of landlords and tenants,” the Supreme Court
has held, “are not per se takings.” F.C.C. v. Fla. Power Corp., 480
U.S. 245, 252 (1987) (collecting cases). States may “require
landlords to comply with building codes and provide utility
connections, mailboxes, smoke detectors, fire extinguishers,
and the like.” Loretto, 458 U.S. at 440. We have found no au-
thority prohibiting something like the Ordinance.
The relocation assistance fee requirement is not a physical
taking just because it transfers wealth. See Yee, 503 U.S. at 529–
30 (“[T]he existence of the [wealth] transfer in itself does not
convert regulation into physical invasion.”). Other permissi-
ble regulations “can … be said to transfer wealth from the one
who is regulated to another.” Id. at 529. Rent control is the
quintessential example. See id. It “often transfers wealth from
landlords to tenants by reducing the landlords’ income and
the tenants’ monthly payments.” Id. Yet that does not make it
a physical taking. See id. at 532.
6 No. 25-1713
Indeed, the Ordinance seems to operate as an indirect (and
clunky) form of rent control. Current and prospective land-
lords know that they will need to offer lease terms more val-
uable than the $10,600 relocation assistance fee to avoid ten-
ants leaving.
We are not alone in our conclusion. The Ninth Circuit re-
solved a similar question in much the same way. See Ballinger
v. City of Oakland, 24 F.4th 1287, 1293 (9th Cir. 2022) (holding
a “relocation fee is not an unconstitutional physical taking” in
part because it resembles “rent control”).
We appreciate that this case is not identical to Ballinger.
There the landlord’s decision to evict tenants triggered the re-
location fee. See id. at 1291. Under Chicago’s Ordinance, how-
ever, tenants decide whether they will renew or opt to receive
the fee. See Chi., Ill. Mun. Code § 5-14-050(a)(1). But we do not
see this distinction as dispositive. Regardless of which party
is the impetus for the termination of the lease, the landlord’s
inability to extend it requires that they assist the tenant in re-
settling. In short, there is no disputing that the Ordinance reg-
ulates an aspect of the landlord-tenant relationship.
C
To be sure, BBLI’s position has something to it. The Su-
preme Court appears to have endorsed the view that “when
the government commands the relinquishment of funds
linked to a specific, identifiable property interest such as a
bank account or parcel of real property, a per se takings ap-
proach is the proper mode of analysis.” Koontz, 570 U.S. at 614
(cleaned up); see also Ballinger, 24 F.4th at 1295 (reading
Koontz the same way). And it has held that a demand for
money satisfied that test when it “direct[ed] the owner of a
No. 25-1713 7
particular piece of property to make a monetary payment,”
and thereby “burdened … ownership of a specific parcel of
land.” Koontz, 570 U.S. at 613. Read broadly, this suggests that
the Ordinance may amount to a physical taking because it di-
rects the owners of particular pieces of property—newly fore-
closed buildings—to make specific monetary payments to
their tenants.
But, in light of the state of today’s law, we are not inclined
to read Koontz so expansively. In Koontz the government re-
fused to grant a landowner permits unless he reduced the size
of his proposed development or paid contractors to improve
some nearby government-owned land. See id. at 601–02. The
Supreme Court viewed practices like this as “functionally
equivalent to other types of land use exactions.” Id. at 612. In
contrast, Chicago’s Ordinance adds no conditions to the re-
ceipt of a benefit, and it applies to an entire class of landown-
ers—those who acquire residential buildings out of foreclo-
sure. Cf. Sheetz, 601 U.S. at 280 (leaving unresolved “whether
a permit condition imposed on a class of properties must be
tailored with the same degree of specificity as a permit condi-
tion that targets a particular development”).
In no way are the trends in the Supreme Court’s recent
takings cases lost on us. See, e.g., Koontz, 570 U.S. at 619 (hold-
ing in 2013 that “the government’s demand for property from
a land-use permit applicant must satisfy” criteria developed
to evaluate whether an unconstitutional taking occurred);
Horne, 576 U.S. at 361 (holding in 2015 that the government’s
acquisition of a percentage of raisins to help regulate the mar-
ket constituted a compensable taking); Knick, 588 U.S. at 194,
206 (holding in 2019 that “[a] property owner may bring a tak-
ings claim under § 1983 upon the taking of his property with-
8 No. 25-1713
out just compensation by a local government” and overruling
a prior case requiring exhaustion of “state procedures for ob-
taining compensation before bringing a federal suit”); Cedar
Point Nursery, 594 U.S. at 162 (holding in 2021 that a regula-
tion requiring union representatives be able to access prop-
erty constituted a compensable taking); Tyler, 598 U.S. at 647
(holding in 2023 that the government’s retention from a for-
feiture sale of more than the homeowner owed in taxes con-
stituted a compensable taking).
We are thus confronted on the one hand with expanding
sets of circumstances that implicate the Takings Clause and
on the other with a specific line of analogous precedent that
applies to the landlord-tenant relationship, see, e.g., Yee, 503
U.S. at 532; Loretto, 458 U.S. at 440; Fla. Power Corp., 480 U.S. at
252. In these situations, the Supreme Court has reminded
lower courts of our role. See Hohn v. United States, 524 U.S.
236, 252–53 (1998) (“Our decisions remain binding precedent
until we see fit to reconsider them, regardless of whether sub-
sequent cases have raised doubts about their continuing vital-
ity.”); see also NLRB v. Constellium Rolled Prods. Ravenswood,
LLC, 43 F.4th 395, 408 n.17 (4th Cir. 2022) (“Accepting our
place, we do our level best to apply the law as it stands, not
as it might one day become.”); Int’l Union of Operating Eng’rs,
Stationary Eng’rs, Loc. 39 v. NLRB, 155 F.4th 1023, 1054 (9th Cir.
2025) (“We only applied the law as it is, compelled by decades
of precedent, not as what we wish, predict, or think it to be.”).
We follow that guidance here.
In the final analysis, then, we focus on the specific line of
cases dealing with the landlord-tenant relationship. And
those precedents are clear that “statutes regulating the eco-
nomic relations of landlords and tenants are not per se tak-
No. 25-1713 9
ings.” Fla. Power Corp., 480 U.S. at 252 (collecting cases). We
see no physical taking.
III
BBLI also challenges the Ordinance as a partial regulatory
taking, or use restriction, that overburdens its ability to use
the property. See Cedar Point Nursery, 594 U.S. at 148. We eval-
uate alleged regulatory takings by balancing the Penn Central
factors, including “the economic impact of the regulation, its
interference with reasonable investment-backed expectations,
and the character of the government action.” Id. at 140 (citing
Penn Cent. Transp. Co. v. City of New York, 438 U.S. 104, 124
(1978)). All three factors favor the City of Chicago.
First, BBLI’s complaint says little about the economic im-
pact of the Ordinance. As this case comes to us at the pleading
stage, BBLI had complete control over the facts before the dis-
trict court. But it did not allege that the Ordinance’s existence
made operating the rental property economically infeasible.
The district court even gave BBLI an opportunity to amend its
complaint, but the firm elected not to do so. See Keene v. Con-
solidation Coal Co., 645 F.3d 844, 850 (7th Cir. 2011) (concluding
that minimal data provided by plaintiff “proves nothing
about the economic impact of the legislation on [the plaintiff]
itself, which is necessary to establish a taking”).
Second, the Ordinance did not interfere with BBLI’s rea-
sonable investment-backed expectations. BBLI took posses-
sion of the property at 5200 North Sheridan Road well after
the Ordinance went into effect. Like any rational actor enter-
ing the residential leasing market in Chicago, it presumably
estimated what percentage of its tenants would demand the
relocation assistance fee as opposed to signing new leases.
10 No. 25-1713
This factor weighs heavily against finding a regulatory tak-
ing. Cf. Goodpaster v. City of Indianapolis, 736 F.3d 1060, 1074
(7th Cir. 2013) (finding no taking and reasoning that bar own-
ers should have anticipated the expansion of a smoking ban
that hurt their businesses).
Third, the Ordinance regulates an aspect of a landlord-ten-
ant relationship. And today’s law is clear that state and local
authorities have broad power over that relationship. This fac-
tor favors Chicago as well. Cf. Connolly v. Pension Benefit Guar.
Corp., 475 U.S. 211, 225 (1986) (“This interference with the
property rights of an employer arises from a public program
that adjusts the benefits and burdens of economic life to pro-
mote the common good and, under our cases, does not con-
stitute a taking requiring Government compensation.”).
IV
BBLI lastly challenges the Ordinance as an unconstitu-
tional condition (also commonly called an exaction). But the
test BBLI asks us to apply is not a good fit for its concerns
about the Ordinance. Regardless, even if we shoehorn the
facts into an unconstitutional conditions analysis, the City still
prevails.
The test BBLI urges us to use normally applies to the per-
mitting process. Because “the government can deny a build-
ing permit to further a ‘legitimate police-power purpose,’
then it can also place conditions on the permit that serve the
same end.” Sheetz, 601 U.S. at 274 (quoting Nollan v. Cal.
Coastal Comm’n, 483 U.S. 825, 836 (1987)). But those “condi-
tions must have an ‘essential nexus’ to the government’s land-
use interest.” Id. at 275 (quoting Nollan, 483 U.S. at 837). They
also “must have ‘rough proportionality’ to the development’s
No. 25-1713 11
impact on the land-use interest.” Id. at 275–76 (quoting Dolan
v. City of Tigard, 512 U.S. 374, 391 (1994)). In essence, the gov-
ernment cannot avoid paying just compensation by acquiring
property or other rights by leveraging its ability to extort con-
cessions indirectly. See Koontz, 570 U.S. at 605–06.
The unconstitutional conditions doctrine is a mismatch
here. BBLI is not asking for permission to build something or
to engage in some other lawful activity for which the City of
Chicago is withholding permission based on a condition. Ra-
ther, the Ordinance directly requires BBLI to pay its tenants a
fee if they do not renew their leases. Chicago is not hiding be-
hind a permitting or similar process. It is mandating the trans-
fer of funds upon a tenant’s decision not to accept the terms
of a new lease offered by the landlord.
But even applying this ill-fitting test, BBLI still falls short
because the City has an interest in keeping its residents
housed. That is the purpose the Ordinance seeks to serve,
providing it with an essential nexus to the government’s in-
terest. And BBLI makes no effort to show that any relocation
assistance fee is disproportional to the impact on Chicago’s
interest. It provides no estimates for actual moving costs, nor
does it explain how it would need to adjust its lease rates to
prevent tenants from taking the fee. We therefore are unable
to find an unconstitutional condition on these facts.
***
We emphasize that our opinion passes no judgment on the
wisdom or utility of the Ordinance. But given our reading of
today’s Takings Clause precedent, BBLI is unable to carry its
burden. That conclusion leaves us to AFFIRM.