Village of River Forest v. Midwest Bank & Trust Co.

The issue in this appeal is whether a municipal ordinance, invalid because the municipality lacked power to adopt it, is validated only by the subsequent enactment of an enabling statute. To resolve this issue we turn to principles well established in the law of municipal corporations. First, however, we will state the material facts.

I

The plaintiff in this litigation was the Village of River Forest, an Illinois municipal corporation. Defendants were Midwest Bank & Trust Co., trustee of a land trust and four individuals, all bachelors, unrelated to each other by birth, adoption or marriage.…