Pre-Development Expenditure of More Than 27% of the Total Projected Development Cost
In Cribbin v. City of Chicago, 384 Ill. App. 3d 878, 893 N.E.2d 1016, 323 Ill. Dec. 542 (2008), the court concluded that the property owners' pre-development expenditure of $ 260,000 was substantial. Cribbin, 384 Ill. App. 3d at 894.
The facts of that case further demonstrate that the owners intended to construct three buildings on the property at a total cost of $ 950,000. Cribbin, 384 Ill. App. 3d at 883.
Accordingly, the $ 260,000 in expenditures found to be substantial in Cribbin represented more than 27% of the total projected cost of the development.