Dist. Ct. did not err in granting defendants-Park District and City's motion for summary judgment in plaintiffs' action seeking to halt construction of Obama Presidential Center in Chicago's Jackson Park, where plaintiffs alleged that defendants' alteration of use of Jackson Park and handing over control of Center's site to Barack Obama Foundation essentially took plaintiffs' property for private purpose in violation to Takings Clause of Fifth Amendment and denied plaintiffs' due process rights under 14th Amendment. Plaintiffs cannot proceed on either claim, since they have no protected interest in public land, and plaintiffs could not rely on public trust doctrine under Illinois state law to create such interest. Moreover, City's judgment that instant transfer and use of property has public purpose is entitled to deference. Also, plaintiffs' due process claim fails, since plaintiffs failed to identify what greater process they were due, especially where City enacted four ordinances approving aspects of Center that followed multiple public hearings. Ct. further found that plaintiffs lacked Article III standing to bring state claims alleging violation of public trust doctrine arising out transfer of park land to Center, where: (1) plaintiffs alleged only that govt. had failed to follow relevant law, while Article III required that plaintiffs to demonstrate injury to their "separate and concrete interests;" and (2) even if construction of Center would damage Jackson Park, relevant showing required plaintiffs to show injury to themselves as opposed to any injury to Jackson Park. Too, plaintiffs could not establish standing as municipal taxpayers, since they could not show that City actually spent tax revenues on any illegal action. Fact that Illinois law would find that plaintiffs had standing to proceed on public trust doctrine claim is irrelevant to any Article III inquiry.
