City Council Regular Meeting
Regular MeetingUrbana, IL · February 8, 2021
Minutes
CITY COUNCIL
MEETING MINUTES
DATE: Monday, February 8, 2021
TIME: 7:00 P.M.
PLACE: *Held virtually due to Governor’s and Mayoral Emergency Orders
The City Council of the City of Urbana, Illinois, met in regular session Monday, February 8, at 7:00pm via
Zoom.
ELECTED OFFICIALS PHYSICALLY PRESENT: Diane Wolfe Marlin, Mayor; Phyllis D. Clark,
City Clerk
ELECTED OFFICIALS PRESENT VIA TELECONFERENCE: City Council Members (CM) Bill
Brown, Bill Colbrook, Shirese Hursey, Jared Miller, Dennis Roberts, Erik Sacks, Maryalice Wu
ELECTED OFFICIALS ABSENT: None
STAFF PRESENT: Jason Liggett, Kay Meharry; Carol Mitten; Lorrie Pearson; Andrea Ruedi, Bryant
Seraphin; Lily Wilcock
OTHERS PRESENT VIA ZOOM: Public Input via Zoom: Allan Max Axelrod; Benjamin Beaupre;
Elderess Melinda Carr; Tracy Chong; Colin Dodson; Haki; Christopher Hansen; Justin Hendrix; John
Kraft; Meghan McDonald; Rev. Dr. Evelyn Underwood
A. Call to Order and Roll Call
With a quorum virtually present, Mayor Marlin called the meeting of the City Council to order at
7:16pm, following a meeting of the Cunningham Township Board.
B. Approval of Minutes of Previous Meeting
CM Miller made a motion to approve the minutes from the January 25, 2021 meeting. Motion
seconded by CM Colbrook and carried by roll call vote as follows:
Aye: Brown, Colbrook, Hursey, Miller, Roberts, Sacks, Wu
Nay: None
C. Presentations and Public Input
1. Comprehensive Plan Website Go-Live Presentation
Senior Advisor for Integrated Strategy Development Andrea Ruedi began the presentation by
saying the City has launched its first community engagement tool, which is the
ImagineUrbana.com website. Ruedi showed several videos on the website and said more segments
will be added. Planner Lily Wilcock was present, and she and Ruedi responded to questions and
concerns from council members.
Public Input via Zoom
Comments via Zoom included: sees some first steps in the Comprehensive Plan; resolution to end
structural racism and achieve racial equity is a great start in publically declaring Urbana’s position and
the people of Urbana must hold city officials responsible in staying true to the principles in the
resolution; academic publishing inaccurate information and it should be retracted; Imagine Urbana log
in and registration should not be required; Urbana Police Department has not apologized for Aleyah
Lewis incident; City should admit its mistakes in regard to FOIA; support resolution for racial equity;
collaborate across systems to end racial disparity; public input during the council and committee
meetings is the only means the public has to voice concerns; concern about Emulsicoat applying for a
lifetime operating permit at current location; concern about Emulsicoat moving to new location;
Edgar County Watchdogs are not trying destroy local governments or install people into local
governments; tired of input being reduced to a few concerns; organizations who help people should
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be available to do that outside of office hours; resolution does not have any action and actual action
should be added to it; new FOIA officer is practicing the same unlawful tactics as the former FOIA
officer.
Public input via email is attached.
D. Council Input and Communications
CM Hursey said the resolution committing to end structural racism, as a resolution has nothing
actionable in it because resolutions do not include actions. The goal was to reach into the past in order
to not repeat it and to have a better future.
CM Wu told council she is working on a resolution that addresses police accountability and de-
escalation. It should be on the agenda for the February 15 Committee of the Whole agenda.
CM Brown said he will have a couple of presentations in the future from the Bicycle and Pedestrian
Advisory Commission including and annual report and a recommendation on the Kickapoo Rail Trail
study from 2018. There will be a new youth member position on the commission for high school
youth, from age 14 to 17.
CM Roberts commented on the Emulsicoat information, and said he spoke with Chris Pressnall, the
Environmental Justice Officer with the Illinois Environmental Protection Agency (IEPA). Pressnall
told him that lifetime permit does not necessarily mean it will be forever, but will be in effect until
further notice or some sort of change, and is only a formality. Pressnall said the outreach officer with
the IEPA is considering holding a public input session to allow residents to ask questions and discuss
their concerns about Emulsicoat.
E Additions to the Agenda
There were none.
F. Unfinished Business
There was none.
G. Reports of Standing Committees
Committee of the Whole – Council Member Bill Brown
1. Consent Agenda
2. Regular Agenda
a. Resolution No. 2021-02-005R: A Resolution Committing to End Structural Racism and
Achieve Racial Equity
CM Brown moved to pass Resolution No. 2021-02-005R. The motion was seconded by CM
Hursey. CM Brown went over the changes made to the resolution by CM Hursey and CM
Wu, which were as follows:
In the seventh paragraph, change WW II to World War II;
An eighth paragraph was added: “WHEREAS, from its founding in 1867 through the
1940's, University of Illinois denied campus housing to Black students, therefore
requiring them to seek out and pay for housing within the black community (north end);
creating additional psychological and physical stress to their college experience; and”;
Paragraph 10 the spelling for Chief Illiniwek was corrected;
Paragraph 11, after the words “from impenitent individuals”, was added: “Nationwide,
Black Americans continue to be marginalized within the health care system and suffer
deleterious outcomes, as exemplified by a death rate from COVID-19 that is 3.57 times
higher than White Americans1. Locally, there is widespread community support for an
offensive former University mascot, local transportation companies discriminate against
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immigrants from Asian countries, and in Urbana, the black community continues to face
disparate outcomes in traffic stops”;
Section 1, in the last sentence, after the words “speak truth” was added “to the hate and
bigotry of white supremacy”, which replaced the words “to the power of white
supremacy”.
After further discussion and comments, the motion to approve Resolution No. 2021-02-005R
was carried by roll call vote as follows:
Aye: Brown, Colbrook, Hursey, Miller, Roberts, Sacks, Wu
Nay: None
H. Reports of Special Committees
There were none.
I. Reports of Officers
City Administrator Carol Mitten reported that the lifetime operating permit Emulsicoat applied for is
something they probably do not need because they can revert back to a prior lifetime operating
permit, and added there no part of the application that requires any findings or analysis regarding
environmental justice. The City has received some of the information it requested from Emulsicoat
and has requested more through the Freedom of Information Act (FOIA). The City is trying to bring
the outreach coordinator from the environmental justice section of the IEPA out to the community,
possibly at a meeting of Sustainability Advisory Commission (SAC), to inform the public about what
is going on at the Emulsicoat facility.
Administrator Mitten said she spoke to American Water officials to check on the status of water
shutoffs. American Water began shut offs again last fall. American Water said residents can call 1-800-
422-2782 and self-certify that they are having financial problems due to Covid and that should be
sufficient to avoid water shut off. There is also a Salvation Army Program called H2O (Help to
Others) which will help people pay their water bills.
Administrator Mitten said the Public Works department is short-staffed because of a couple of cases
of Covid, and quarantining. Remaining staff is working through trying to clear streets and spread salt
mainly on primary and secondary routes.
J. New Business
1. Mayoral Staff/Board and Commission Appointments
a. Traffic Commission – Council Member Erik Sacks
b. City Engineer – Tim Cowan, Interim Public Works Director
c. FOIA Officer – Ross McNeil
Mayor Marlin presented the appointments and said Erik Sacks would replace former Council
Member Eric Jakobsson on the Traffic Commission. Interim Public Works Director Tim Cowan
will be appointed City Engineer. Ross McNeil will be appointed the FOIA Officer. City
Administrator Mitten clarified that state law requires council to approve the appointment of the
FOIA Officer.
CM Hursey moved to approve the staff, board and commission appointments of CM Erik Saks to
the Traffic Commission, Tim Cowan as City Engineer and Ross McNeil as FOIA Officer. Motion
seconded by CM Colbrook.
CM Miller said he would like to see more information about Ross McNeil and would also like to be
able to speak to him before approving his appointment. He added he will try to bring forward
legislation to change in the appointment process, giving council the chance to have more input.
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After further discussion and clarification, the motion to approve the Mayoral staff, board and
commission appointments was carried by roll call vote as follows:
Aye: Brown, Hursey, Colbrook, Roberts, Sacks, Wu
Nay: Miller
K. Adjournment
With no further business before council, Mayor Marlin declared this virtual meeting adjourned at
9:04pm.
Kay Meharry
Recording Secretary
This meeting was recorded and is viewable on-demand.
Minutes Approved: February 22, 2021
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From:
To: !City Council
Subject: public comment
Date: Monday, February 08, 2021 4:19:25 AM
*** Email From An External Source ***
Hello. I live in ward 7. I am writing this as a result of hearing large amounts of false statements, untrue information,
and conspiracy theories during public comment at council meetings. Each meeting, the same group of people, some
that do not actually live in town, attend public comment and spread nonsense. This is a waste of time for both city
council and for residents that want to learn about actual city business. As a result, I think that council needs to
change the rules for public comment in order to prevent these people from spreading more lies. Public comment
needs to be reserved for residents that have actual comments and ideas, not for conspiracy theorists.
Thank you
Ben Rafter
Sent from my iPhone
From:
To: !City Council
Subject: PUBLIC INPUT - Resolution No. 2021-02-005R (February 8, 2021 City Council Meeting)
Date: Monday, February 08, 2021 1:11:08 PM
*** Email From An External Source ***
Dear Mayor Marlin and Members of the Urbana City Council:
Resolution No. 2021-02-005R – A Resolution Committing to End Structural Racism and Achieve Racial
Equity is a great start in publicly declaring the City of Urbana’s general position, and the intent has been
stated to bring awareness of this practice in the history of the City of Urbana.
Based on the explanation at the February 1 Committee of the Whole meeting, my understanding is there
will not be specific or future actions included at this time for the City of Urbana.
Therefore, the People of Urbana must continue to hold our city officials accountable to stand on the
principles outlined in the Resolution to ensure that racial equity is achieved. Both now and in the transition
to new leadership, we know that you have an awesome responsibility in guiding city government for the
People of Urbana. We appreciate the service of our city officials in working toward this end.
I am suggesting stronger language in a few more areas and other minor edits (highlighted in red in the
following information copied below) for your consideration in the final approved Resolution.
I would like this information to be included in the record of Public Input for tonight’s meeting and I hope to
share verbally as well.
Respectfully Submitted,
Elderess Melinda Carr
Resident of Urbana
Address: 1308 West Tremont Street
RESOLUTION NO. 2021-02-005R
A RESOLUTION COMMITTING TO END STRUCTURAL RACISM AND ACHIEVE RACIAL EQUITY
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WHEREAS, the City of Urbana endeavors to lead the pursuit of racial equality and justice; and
WHEREAS, equality does not come at the expense of another, but ensures that everyone gets what they
need to be a full participant in their community; and
WHEREAS, white supremacy defies what it means to be American by denying the ideals prescribed in
the Declaration of Independence and Civil Rights enshrined in the United States Constitution; and
WHEREAS, in order for our community to heal and achieve racial equity, it is necessary to recognize and
confront the history of injustice; and
WHEREAS, in the City of Urbana, the history of white supremacy and racial oppression began with the
first white settlements by the French, with slavery being legal and present in the territory through British
and colonial rule until the Northwest Ordinance of 1787. From then on, territorial black laws and unlawful
practice purposefully perpetuated slavery and racial oppression, and this practice continued despite the
exclusion of slavery when the State was established in 1818. By an 1824 referendum for a constitutional
amendment, 42% of the vote was still in favor of slavery; and
WHEREAS, despite nominal legal progress, Jim Crow laws and white supremacy continued to be
prevalent in Champaign-Urbana. The Ku Klux Klan maintained a significant local presence, operating out
of the Illinois Theater in Urbana and holding events with upwards of 3,000 members at a time when the
County’s population was less than 60,000; and
WHEREAS, issues of segregation and racial oppression became particularly acute in the decades
following World War II (WWII), following the increase in the black population of Champaign-Urbana. Black
citizens were systematically and illegally excluded from white neighborhoods through subdivision
covenants, developer, realtor, landlord, seller, and lending practices and were de facto confined to the
Page 2 of 4 ‘north end’. Residents were further exploited by predatory rents in slum rentals and would-be
homeowners faced inflationary supply constraints that actively diminished wealth creation. By 1961, the
community was the most segregated community in the State. Furthermore, the north end neighborhood
was underinvested in public infrastructure, with unpaved roads, unlit streets and other lacking
infrastructure making life more difficult, unsafe, and expensive for residents; and
WHEREAS, the racial oppression of white supremacy was expansive, including more than just housing
and was prevalent and punishing for employment opportunities. Regardless of qualifications, black
workers were systematically discriminated against in hiring, where the only jobs made available were:
lower paying, manual labor, more insecure, and segregated. In 1968, the unemployment rate in
Champaign-Urbana was 2.6 percent for whites, and between 12 and 20 percent for blacks, depending on
the season. Especially oppressive was the lack of employment opportunities for black professionals.
Local black residents, having completed a college degree, were unable to find employment in
Champaign-Urbana and were forced to leave the area to find appropriate employment. As late as 1968,
there were no local black doctors, lawyers, firefighters, and only recently had bona fide black police
officers been hired. The lack of black professionals meant that the black community faced systematic
discrimination, with no alternative local option, from professions pertaining to wealth, health, public safety,
and the law; and
WHEREAS, the history of white supremacy also extends to the racial discrimination of all non-white
people. The land now known as Champaign County was originally home to the Peoria, Kaskaskia,
Piankashaw, Wea, Miami, Mascoutin, Odawa, Sauk, Mesquaki, Kickapoo, Potawatomi, Ojibwe, and
Chickasaw Nations. Many were removed from the area in 1819 with the remaining native population
forcefully removed in 1832 following the Black Hawk War. This history was then White-washed and the
native population was caricatured in a racist demeanor for decades by the Chief Illiniweck mascot
representing the University and our community; and
WHEREAS, white supremacy and racial discrimination continue to this day, both institutionalized and
from impenitent individuals, where there is widespread community support for
Page 3 of 4 an offensive former University mascot, and where local transportation companies
discriminate against immigrants from Asian countries, and in Urbana, where the black community
continues to face disparate outcomes in traffic stops; and
WHEREAS, repercussions of this history and current practice run deep. Community, social, educational,
and economic outcomes for non-whites all suffer from the physical and psychological consequences of
racism; and these outcomes sustain themselves long after the original sins and sinners perish; and
WHEREAS, the effects of racism are still profoundly felt today in Urbana. It affects the health and wealth
of individuals and the entire community, having been declared by the Champaign-Urbana Public Health
District to be a public health crisis1. It will not be overcome without a concerted and sustained effort
commitment by all.
NOW, THEREFORE, BE IT RESOLVED by the City Council, of the City of Urbana, Illinois, as follows:
Section 1. The City hereby rejects the institutionalized legacy of racism and white supremacy that is our
history and afflicts our community today. While our community and government have continued to
evolves away from the habitual practice and widespread acceptance of racism and white supremacy and
is today becoming a more loving community seeking to fulfill the promise of a more perfect Union, we are
all inhabitants of an inherited prison of institutionalized inequalities of free and fair existence. If the City is
to actualize the commandments principles, rights, and powers of Our Constitution, we must be conscious.
The City of Urbana will strive to purge the perpetuation of discrimination that is institutionalized in our
society through the power of its policies, procedures, and attitudes. The Mayor and City Council will
henceforth speak truth to the power hate and bigotry of white supremacy and shall publicly denounce it
whenever its attitudes or effects become clear within our community. [1] See CUPHD resolution. Much
thanks to City of Evanston, Illinois Resolution for inspiring the format of this resolution and for the
Champaign County Historical Archives staff at The Urbana Free Library, especially Tom Kuiper, for the
historical research, including providing the dissertation Injustice sheltered: race relations at the University
of Illinois and Champaign-Urbana, 1945-1962. Their research allows this resolution to speak truth to
history of white supremacy in Urbana and Champaign County.
Page 4 of 4 Section 2. The City of Urbana recognizes that it will take additional effort commitment,
courage, and determination to align our actions with our aspirations in order to carry out the vital needs
expressed by the People of Urbana. The subversiveness of white privilege includes the double standard
of imposing responsibilities and restrictions when there are unequal rights and inequitable opportunities.
The City resolves to recognize and value diversity in its policies, personnel, and investment; the City will
seek to ensure that there is harmony between equal and fair processes and equitable results. In the
pursuit of equity, wherever it is feasible and just, the City shall use all methods and methodologies at our
disposal through our Departments, City Council, Boards, and Commissions. The City shall resolve to
constantly challenge ourselves and to become a strong leaders in creating a government, community,
society, and economy unshackled by the past, unleashing progress and prosperity to their full potential for
all of our residents and business owners so that we may continue moving forward to form a more perfect
Union here in the City of Urbana.
Agenda
URBANA CITY COUNCIL MEETING
DATE: Monday, February 8, 2021
TIME: 7:00pm
PLACE: *to be held virtually via Zoom (400 South Vine Street, Urbana, IL 61801)
AGENDA
A. CALL TO ORDER AND ROLL CALL
B. APPROVAL OF MINUTES OF THE PROCEEDINGS OF REGULAR AND SPECIAL
MEETINGS
1. January 25, 2021
C. *PRESENTATIONS AND PUBLIC INPUT
1. Comprehensive Plan Website Go-Live Presentation
2. Public Input
D. COUNCIL INPUT AND COMMUNICATIONS
E. ADDITIONS TO THE AGENDA
F. UNFINISHED BUSINESS
G. REPORTS OF STANDING COMMITTEES
Committee Of the Whole - (Council Member Shirese Hursey)
1. CONSENT AGENDA
2. REGULAR AGENDA
a. Resolution No. 2021-02-005R: A Resolution Committing to End Structural Racism and
Achieve Racial Equity – CM Hursey/Wu
H. REPORTS OF SPECIAL COMMITTEES
I. REPORTS OF OFFICERS
J. NEW BUSINESS
1. Mayoral Staff/Board and Commission Appointments
a. Public Works Interim Director – City Engineer
b. FOIA Officer – Ross McNeil
c. Traffic Commission – City Council Member Erik Sacks
K. ADJOURNMENT
*Due to the Governor Pritzker and Mayoral Emergency Covid-19 Orders, the Urbana City Council
Chambers will be not be open to the public during this meeting. Council Members will meet remotely
using Zoom Webinar. You may watch the meeting on streaming services, or on Urbana Public Television,
or attend via Zoom.
You are invited to a Zoom webinar.
When: Feb 8, 2021 06:30 PM Central Time (US and Canada)
Topic: Cunningham Township Board / Urbana City Council
Please click the link below to join the webinar:
https://us02web.zoom.us/j/85294125038
Or iPhone one-tap :
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US: +13126266799,,85294125038# or +13017158592,,85294125038#
Or Telephone:
Dial(for higher quality, dial a number based on your current location):
US: +1 312 626 6799 or +1 301 715 8592 or +1 929 205 6099 or +1 346 248 7799 or +1 669 900
6833 or +1 253 215 8782
Webinar ID: 852 9412 5038
International numbers available: https://us02web.zoom.us/u/kbcomv9OQr
PUBLIC INPUT
The City of Urbana welcomes Public Input during open meetings of the City Council, the City Council’s
Committee of the Whole, City Boards and Commissions and other City-sponsored meetings. Our goal is to
foster respect for the meeting process, and respect for all people participating as members of the public
body, city staff, and general public. The City is required to conduct all business during public meetings. The
presiding officer is responsible for conducting those meetings in an orderly and efficient manner.
Public Input will be taken in the following ways:
Zoom Webinar Participant
Click on the link listed in the agenda to join the Webinar. You must provide your name and email address in
order to join the Webinar. If you wish to speak during Public Input, “raise your hand” and wait to be called
on by the meeting host. You must state your first and last name for the meeting record. Participants will be
muted except when they are called on to speak; video will remain off for all members of the public when
speaking.
Telephone Participant
Call the phone number listed on the Agenda. Enter the Webinar ID followed by the # key. All callers are
muted by default. If you wish to speak, “raise your hand” by pressing *9 once. When you are called on by
the host or presiding officer you will be un-muted. You must state your first name and last name for the
meeting record.
Email Input
Public comments must be received prior to the closing of the meeting record (at the time of adjournment
unless otherwise noted) at the following: citycouncil@urbanaillinois.us. The subject line of the email must
include the words “PUBLIC INPUT” and the meeting date. Your email will be sent to all City Council
members, the Mayor, City Administrator, and City Clerk. Emailed public comments labeled as such will be
incorporated into the public meeting record, with personal identifying information redacted. Copies of
emails will be posted after the meeting minutes have been approved.
Written Input
Any member of the public may submit their comments addressed to the members of the public body in
writing. If a person wishes their written comments to be included in the record of Public Input for the
meeting, the writing should so state. Written comments must be received prior to the closing of the
meeting record (at the time of adjournment unless otherwise noted).
Verbal Input
Protocol for Public Input is one of respect for the process, and respect for others. Ridicule, obscene or
profane language, lack of respect for others, and personal attacks are not acceptable behavior. Public Input
shall not be used to air personal grievances. Speakers should address all comments to the public body as a
whole and not to individual members or City staff.
Public comment shall be limited to no more than four (4) minutes per person. The Public Input portion of
the meeting shall total no more than one (1) hour, unless otherwise shortened or extended by majority vote
of the public body members present. The presiding officer or the city clerk or their designee, shall monitor
each speaker's use of time and shall notify the speaker when the allotted time has expired. All public
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comments should be addressed to the public body as a whole. A person may participate and provide Public
Input once during a meeting and may not cede time to another person, or split their time if Public Input is
held at two (2) or more different times during a meeting. The presiding officer may give priority to those
persons who indicate they wish to speak on an agenda item upon which a vote will be taken.
The presiding officer or public body members shall not enter into a dialogue with citizens. Questions from
the public body members shall be for clarification purposes only. Public Input shall not be used as a time for
problem solving or reacting to comments made but, rather, for hearing citizens for informational purposes
only.
Accommodation
If an accommodation is needed to participate in a City meeting, please contact the City Clerk’s
Office at least 48 hours in advance so that special arrangements can be made using one of the following
methods:
Phone: 217.384.2366
Email: CityClerk@urbanaillinois.us
*In order to maintain reasonable decorum at a public meeting, the presiding officer of the meeting shall
have the authority to raise a point of order and provide a verbal warning to a speaker who uses abusive,
harassing, threatening, or defamatory language, or who engages in disorderly conduct that disrupts,
disturbs, or otherwise impedes the orderly conduct of a meeting. Any member of the public body
participating in the meeting also may raise a point of order with the presiding officer and request that they
provide a verbal warning to a speaker. If the speaker refuses to cease such remarks or conduct after being
warned by the presiding officer, the presiding officer shall have the authority to mute the speaker’s
microphone and/or video presence at the meeting. The presiding officer will inform the speaker that they
may send the remainder of their remarks via email to the public body for inclusion in the meeting record.
*Definitions of Types of Language and Conduct That May Warrant Verbal Warning:
“Abusive” means harsh, violent, profane, or derogatory language which would demean the dignity of an
individual or which is intended to humiliate, mock, insult or belittle an individual.
https://www.lawinsider.com/dictionary/abusive-language
“Harassing” means to annoy or bother someone in a constant or repeated way; to make repeated attacks
on another person.
https://www.learnersdictionary.com/definition/harass
“Threatening” means to say that you will harm someone or do something unpleasant or unwanted
especially in order to make someone do what you want.
https://www.learnersdictionary.com/definition/threaten
“Defamatory” means a statement or communication that tends to harm a person's reputation by
subjecting the person to public contempt, disgrace, or ridicule, or by adversely affecting the person's
business. A statement that is likely to lower that person in the estimation of reasonable people and in
particular to cause that person to be regarded with feelings of hatred, contempt, ridicule, fear, or dislike.
Black's Law Dictionary (11th ed. 2019)
Citations that Authorize the Presiding Officer to Bar Offensive Language During Public Comment:
The following citations provide the legal basis for adopting UCC Section 2-5(b)(1)(d) that allows the
presiding officer of a City Council, Committee of the Whole, or a City-sponsored board or commission
regulate “abusive, harassing, threatening, or defamatory language” during public comment. The following
Attorney General binding opinions and case law essentially classify abusive, “harassing, threatening and
defamatory language as “manner”, not “content”, of speech that can be reasonably regulated under the
First Amendment. UCC Section 2-5(c) (Ordinance No. 2020-09-049. Attorney General binding opinion
numbers 2019 PAC 59187, 2018 PAC 55462, 2016 PAC 45349; Milestone v. City of Monroe, Wisconsin, 665
F.3d 774, 783-784 (7th Cir. 2011); Vega v. Chicago Board of Education, 338 F.Supp.3d 806, 811 (N.D. Ill.
2018); Sandefur v. Vill. of Hanover Park, 862 F.Supp.2d 840, 847 (N.D. Ill. 2012); I.A. Rana Enterprises, Inc. v.
City of Aurora, 630 F.Supp.2d 912, 920-923 (D.C. N.D. 2009).
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