2026-09-10 · Illinois · Courts

What happened. The Illinois Appellate Court, First District, Fourth Division, decided two companion administrative-review cases brought by the same South Barrington family, and affirmed the Illinois Human Rights Commission in both. Both are Rule 23 orders and are not precedential.¹

Schoff v. Lakeshore Estates Homeowners Ass'n, 2026 IL App (1st) 250147-U — filed March 5, 2026, against the association.

Schoff v. Illinois Human Rights Comm'n, 2025 IL App (1st) 250148-U — filed December 4, 2025, against the Village of South Barrington.

The facts

The owners, on a stated religious calling, housed asylum seekers, missionaries and refugees in their South Barrington home, sometimes renting rooms. The association enforced neutral covenants against them. They charged religious discrimination and harassment under the Illinois Human Rights Act.

The holding against the association

The Commission's decision sustaining the Department of Human Rights' dismissal for lack of substantial evidence was affirmed. The court's language is categorical: “[T]here was a complete lack of evidence that the Association subjected the Schoffs to discriminatory terms or conditions on the basis of religion, or harassed them on the basis of religion.”

Because the record was empty, the Commission had no obligation to exercise its discretion under 775 ILCS 5/8-103(B) or 56 Ill. Adm. Code § 5300.470 to investigate further. Also cited: 775 ILCS 5/1-103(N), 5/3-105.1, 5/8-111(B)(1)-(2).

The companion case against the Village

1. Schoff v. Lakeshore Estates Homeowners Ass'n, 2026 IL App (1st) 250147-U (Rule 23 order, March 5, 2026) ↩
2. Schoff v. Illinois Human Rights Comm'n, 2025 IL App (1st) 250148-U (Rule 23 order, December 4, 2025) ↩
3. Illinois Department of Human Rights, legislative updates and protected classes in housing ↩