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Residency -- Continuing Requirements

     A federal appeals court has upheld the city of Milwaukee’s residency requirement for law enforcement and emergency personnel. The city’s charter at one point mandated for all municipal employees live within the city limits, but the legislature in 2013 made such a blanket requirement illegal under state law, exempting only requirements that law enforcement, fire, or emergency workers live within 15 miles of jurisdictional boundaries. The city attempted to enforce its original residency rules under the state constitution’s home rule provision, but that was rejected by the state supreme court. The city then required that every law enforcement, fire, and emergency worker reside within 15 miles of city limits, giving them six months to comply, with extensions available for hardship situations. The federal appeals court upheld this, finding no constitutional right for such employees to be free of residency restrictions, which violated neither substantive nor procedural due process. Milwaukee Police Association v. City of Milwaukee, #16-4151, 2017 U.S. App. Lexis 7889  (7th Cir.).  

     The City of Milwaukee has imposed a residency requirement on city employees since 1938. In 2013, the Wisconsin state legislature passed a law banning such requirements. The city continued to enforce the residency rule, claiming it could do so under the home rule provisions of the state Constitution. A police union sued, claiming that the statute trumped the home rule provisions. The Wisconsin Supreme Court agreed, finding that the statute barred the city from enforcing its residency requirement. Black v. City of Milwaukee, #2014-AP-000400, 2016 WI 47, 2016 Wisc. Lexis 155.
     A unanimous decision of an intermediate Ohio appeals court struck down a Cincinnati city ordinance barring all city employees from living outside the state of Ohio. It found the city ordinance in conflict with a state law barring the imposition of residency requirements by political subdivisions with the exception of requiring certain employees to live no further away than adjacent counties to ensure adequate response times to emergencies or disasters. With that sole exception, employees of a governmental entity in Ohio have the right to live anywhere they want. Because the city ordinance was in conflict with the state statute, it was deemed void. Cincinnati v. State, #C-110680, 2012 Ohio 3162, 2012 Ohio App. Lexis 2810.
     Ohio Supreme Court, followed by a second ruling in an appellate court, upholds a statute prohibiting Ohio municipalities from enforcing residency requirements, even when enacted pursuant to a Home Rule provision in the state's constitution. Missig v. Cleveland Civ. Serv. Cmsn., 2010 Ohio 2595, 2010 Ohio App. Lexis 2155 (8th Dist. 2010), relying on Lima v. State, 122 Ohio St.3d 155, 2009 Ohio 2597, 909 N.E.2d 616 (2009).
     Ohio appellate panel rejects a suit filed by a civil service employee who was terminated for violating a residency requirement. The employee failed to exhaust his administrative remedies and challenged his separation by initiating collateral litigation. McNally v. City of Cleveland, #92697, 2010 Ohio 512, 2010 Ohio App. Lexis 452 (8th Dist.).
     Ohio statutes §9.481, which prohibits municipalities from imposing a residency requirement as a condition of employment, is a matter statewide interest, controlled by the legislature, and supersedes home rule powers. AFSCME L-74 v. City of Warren, #2007-T-0110, 2008 Ohio App. Lexis 3298, 2008 Ohio 3905 (11th Dist.).
     Ohio appellate court declines to issue a writ ordering a city to reinstate a police officer who was fired for violating a municipal residency ordinance, which may be invalid. "...it is well-established that an administrative appeal is an adequate remedy for appealing the termination of a police officer." Ohio ex rel. Cleveland Police Pat. Assn. v. City of Cleveland, #90554, 2008-Ohio-325, 2008 Ohio App. Lexis 273, 183 LRRM (BNA) 2829 (8th App. Dist).
     Four appellate courts overturn a 2006 Ohio law, R.C. 9.481(B)(1), prohibiting municipalities from enacting residency requirements. Ohio charter cities may continue to enforce residency regulations for firefighters, police officers and other employees. City of Cleveland v. State, #89486, 2008 Ohio App. Lexis 2246, 2008-Ohio-2655 (8th Dist.); City of Dayton v. State, #22221, 2008 Ohio App. Lexis 2179, 2008-Ohio-2589 (2nd Dist.); City of Lima v. State, #1-07-21, 2007-Ohio-6419 (3rd Dist.); State v. City of Akron, #23660, 2008-Ohio-38 (9th Dist.).
     Ohio appellate panel affirms a trial court decision that management failed to prove that a firefighter violated the city's residency requirement with reliable, probative, and substantial evidence. The appellant had purchased the second home to operate his secondary business, installing windows, and not to live in. Ruck v. City of Cleveland, #89564, 2008-Ohio-1075, 2008 Ohio App. Lexis 952 (8th Dist.).
     In a 2-to-1 holding, the Sixth Circuit rejects an appeal by Cleveland firefighters who challenged a city residency requirement on the right to travel, vagueness and equal protection claims; "it is rational for a city to treat firefighters differently from other city employees." Assn. of Cleveland Fire Fighters, IAFF L-93 v. City of Cleveland, #06-3823, 2007 U.S. App. Lexis 22680 (6th Cir.).
     Arbitrator finds that absent a valid state law prohibiting employee residency requirements, management had just cause to terminate a police officer for living outside of city. City of Youngstown and Youngstown PBA, Case #07-50545, 123 LA (BNA) 986 (Skulina, 2007).
     N.Y. City requirement that city workers who live outside the city limits must pay a city earnings tax on all income, as if they were residents, is valid. Fleming v. Giuliani, #2004-175, 3 N.Y.3d 544, 821 N.E.2d 959 (NY 2004). {N/R}
     Arbitrator finds that a firefighter who owned eight homes was a lawful resident of city, where an investigator based his conclusions on seeing the firefighter at another property four times in a 70-day period. City of Barberton and Barberton Prof. Fire Fighters, L-329 , 120 LA (BNA) 1268, FMCS Case #040209/52328 (Goggin, 2005). {N/R}
     Federal appeals court upholds the termination of a city employee for residency violations. Although the employee claimed that management had been aware that he lived only two days per week within the city limits he failed to prove that the city council was aware of or approved of his living arrangements. Gusewelle v. City of Wood River, #03-2100, 2004 U.S. App. Lexis 14088 (7th Cir. 2004). {N/R}
     Arbitrator concludes that a 7-mile requirement means "as the crow flies" and not vehicle miles. Response time has never been a problem in the city. City of Robinson and Illinois FoP Labor Council, 118 LA (BNA) 1276 (Suntrup, 2003). [Dec FP 2003]
     Illinois appellate court affirms an interest arbitration award, which overrides a town residency ordinance. A residency requirement is a bargainable issue in municipalities outside Chicago. Town of Cicero v. IAFF L-717, #1-01-3931, 788 N.E.2d 286, 2003 Ill. App. Lexis 389, 272 Ill. Dec. 982 (1st App. Dist. 2003). [2003 FP Sep]
     Massachusetts appellate court allows a city and union to agree to a residency requirement for all newly hired officers, and exempting current employees. Brockton Police Assn. v. City of Brockton, #01-P-932, 57 Mass.App.Ct. 671, 785 N.E.2d 702, 2003 Mass. App. Lexis 368, 172 LRRM (BNA) 2408 (2003). {N/R}
     Arbitrator finds that a city did not have just cause to discharge a firefighter who owned a house in the city, but also had a residence outside the city in which his wife and child resided. The city ordinance did not prohibit employees from alternatively occupying more than one residence. City of Warren, Ohio and IAFF L-204, 118 LA (BNA) 129, FMCS Case #02/12588 (Duff, 2003). {N/R}
     Members of the Wyoming National Guard who were dismissed for failing to meet the state's newly enacted residency requirements are entitled to reinstatement because the requirement violates the Privileges and Immunities Clause. The decision is grounded on the fact that the National Guard is peculiarly a federal and state agency. Nelson v. National Guard Assn. (Wyoming), #00-8039/93, 2002 U.S. App. Lexis 13267 (10th Cir. 2002). {N/R}
    Residency requirement of City of Chicago for employees stationed at O'Hare airport is constitutional. Fedanzo v. City of Chicago, #1-01-0582, 2002 Ill. App. Lexis 413 (Ill. App. 2002). [N/R]
    Arbitrator upholds the termination of a police officer who claimed that he resided in his cousin's basement, but filed tax returns and sought a homeowner's tax exemption for property he owns in an adjacent city. Town of Cicero and IL FOP, FMCS Case #011120/02420-A, 116 LA (BNA) 1322 (Goldstein, 2001). [N/R]
    Arbitrator sustains an officer's dismissal. His claim that a farmhouse was a second home and that he and his wife shared a condo with his mother-in-law was not credible. Although five or six surveillances, over a three-month period, were not enough proof, a statement from the in-law and various documents proved the city's case. City of Columbus and FOP L-9, FMCS Case #00/01343, 116 LA (BNA) 586 (Kohler, 2001).   [2002 FP Apr]
     Arbitrator reinstates an officer who had dual residences, on the condition that he vacates the second home. Cicero (Town of) and IL FOP L-2, 115 LA (BNA) 8 (Winton, 2000). Also see Cicero (Town of) and IL FOP, FMCS #99/14409, 115 LA (BNA) 740 (Nathan, 2001). [2001 FP 27-8]
     Federal appeals court upholds a requirement that city firefighters live within the home county. Fiscal ties between the two governments provided a rational basis for the rule. Kiel v. City of Kenosha, #00-2651, 236 F.3d 814, 2000 U.S. App. Lexis 31314. [2001 FP 12-13]
     Minnesota appellate court holds that the adoption of a response-time residency requirement is a managerial right, not subject to mandatory bargaining. Law Enf. Labor Serv. v. Co. of Cook, #C0-99-397, 1999 Minn. App. Lexis 1045 (Unpub.). [2000 FP 19-20]
     Boston settles two residency-termination cases where the workers had homes in the suburbs to accommodate their disabilities. McDonald v. Menino, #96-10825 and Sheehan v. Menino, 37 (1840) G.E.R.R. (BNA) 1564 (D.Mass. 1999). [2000 FP 27]
     A city may enforce a continuing residency requirement for police officers, even if state's police civil service law does not have address the subject. Morgan v. City of Wheeling, 516 S.E.2d 48, 1999 W. Va. Lexis 36. {N/R}
     Federal jury awards three Calumet City IL officers $4.75 million. Their terminations for residency violations were found to be subterfuge for not supporting the mayor's reelection campaign. Mora v. Genova, #97 C 7765, 1998 U.S. Dist. Lexis 2258 and 13216 (N.D. Ill. 1999). [1999 FP 93]
     Appellate court sustains termination of NYPD officer. Testimony he lived in the city was not credible; penalty upheld, in spite of his good service record. Cullen v. Bratton, 658 N.Y.S.2d 26, 1997 N.Y. App.Div. Lexis 5925. [1998 FP 106]
     A demand to exempt firefighters from residency requirements was a mandatory subject of bargaining in New Jersey. City of Perth Amboy, NJ PER ¶ 29006 (1998). {N/R}
     Fire dept. in N.Y. could not terminate a probationary firefighter for misrepresenting his address, because residency requirements are illegal in that state. Castner v. Griffith, 631 N.Y.S.2d 1018 (Sup. 1995). [1996 FP 76]
     Missouri appellate court affirms termination of KCPD officer for violating city's residency rule. Use of his uncle's address was a sham, as officer principally stayed outside the city with his wife. Fritzhall v. Bd. Police Cmsnrs., 868 S.W.2d 20 (Mo.App. 1994). {N/R}
     City ordinance establishing a residency requirement was unlawful, because a state law prohibited such requirements. Ashland (City of) v. F.O.P. L-3, 888 S.W.2d 667 (Ky. 1994). {N/R}
     A divided Third Circuit upholds a municipal continuing residency ordinance, attacked under the Constitution's “Privilege and Immunities” clause. Salem Blue Collar Workers Assn. v. City of Salem, 33 F.3d 265 (3rd Cir.); cert.den. 115 S.Ct. 1105 (1995). [1995 FP 11]
     New Hampshire supreme court upholds constitutionality of a municipal continuing residency requirement. Seabrook Police Assn. v. Town of Seabrook, 635 A.2d 1371 (N.H. 1993). {N/R}
     N.J. appellate court overturns state employment relations commission. Residency requirements are not subject to bargaining laws. Newark v. Patrolmen's Benev. Assn. Local 3, 272 N.J.Super. 31, 639 A.2d 333 (App. 1994). [1994 FP 140]
     Federal Court upholds New Jersey city's residency law, which was challenged on equal protection and privileges and immunities grounds. Salem Blue Collar Workers v. City of Salem, 832 F.Supp. 852 (D.N.J. 1993). {N/R}
     Residency requirements: racially discriminatory impact. See Newark Branch NAACP v. Twp. of W. Orange, 786 F.Supp. 408 (D.N.J. 1992). {N/R}
     Ohio appellate court requires city to bargain with firefighters over residency requirements. City of St. Bernard v. State Empl. Rel. Bd., 74 Ohio App.3d 3, 598 N.E.2d 15 (1991). [1993 FP 19]
     Georgia supreme court holds that state statute prohibiting municipal residency requirements does not prevent a city from enforcing a residential distance limit. Dixon v. Perry, 416 S.E.2d 279 (Ga. 1992). [1993 FP 45]
     Iowa Supreme Court upholds a ten-mile residency ordinance for firefighters, police officers and essential personnel. Court finds rational relationship between ordinance and employee rights; no violations of the Equal Protection Clause. Clinton Police Barg. Unit v. City of Clinton, 464 N.W.2d 875 (Iowa 1991). [1992 FP 44]
     Preapplication residency requirement violated the Equal Employment Opportunity Act. U.S. v. City of Warren, 759 F.Supp. 355 (E.D. Mich. 1991). [1992 FP 76]
     Federal court enjoins N.J. town's residency requirement for fire, police and other positions. Law had a disparate impact on nonresident black applicants. NAACP v. Town of Harrison, 749 F.Supp. 1343 (D.N.J. 1990).
     Iowa appellate court upholds residency requirement and sustains officer's termination. Merritt v. Council Bluffs Civ. Serv. Cmsn., 458 N.W.2d 867 (Iowa App. 1990).
     Jury finds that K.C. police internal affairs investigators trespassed to get evidence that another officer was in violation of residency requirements. Nominal damages awarded. [Larry] Riebesell v. [Thomas] Walker [and John Cornell], Jackson Co., Mo., Cir. Ct. (1990).
     Marital rights: a fire dept. employee in one jurisdiction married a firefighter in another; both communities had residency requirements. The appellate court upheld the termination of the one spouse who moved, holding that not every regulation relating to the incidents of marriage is unconstitutional. Campbell v. City of Allen Park, 829 F.2d 576 (6th Cir. 1987). {N/R}
     Iowa Supreme Court upholds termination of deputy sheriff for living outside the county limits. Hawkinson v. Civil Serv. Cmsn., 431 N.W.2d 350 (Iowa 1988).
     Waiver: Wisconsin Supreme Court enforces a contract provision which waived enforcement of residency ordinance for police and fire, if the city waived enforcement for other municipal employees. City of Madison v. Madison Prof. Police Ofcrs. Assn., 425 N.W.2d 8 (Wis. 1988).
     Statute can lawfully require firefighters to live in that state, even though residency within employing city is not required. Winkler v. Spinnato, 523 N.Y.S.2d 530 (A.D. 1987).
     Unequal enforcement of residency policy could give rise to a civil rights suit, if variances are proved. Prescott v. Pritchett, 509 So.2d 222 (Ala. Civ. App.), reversing 509 So.2d 227 (Ala. 1987).
     Rhode Island holds that “home rule” cities, with legislative approval, may adopt residency requirements in derogation of state law. Int. Assn. of Firefighters v. Napolitano, 516 A.2d 1347 (R.I. 1986).
     Clause requiring residency for firefighters unless city waives requirement for other employees, excused enforcement, when city waived requirement for bus drivers. City of Madison v. L-311 IAFF, 394 N.W.2d 766 (Wis. App. 1986).
     Forty-mile residency rule upheld as reasonable; no need to adopt a travel time requirement. IAFF v. San Leandro, 226 Cal.Rptr. 238 (App., 1986).
     Exemptions: City can exempt those who are then employed from new residency provision; former employees must establish residency. Hayslip v. City of Akron, 21 Ohio App. 165; 486 N.E.2d 1160.
     Residency rules not management prerogatives; may be subject of bargaining and mandatory binding arbitration. Twp. of Moon v. Police Officers, 498 A.2d 1305 (Pa. 1985).
     Health needs: Hyperkinetic child no excuse for living in the next state. Chicago's residency law enforced against firefighter. Hameetman v. City of Chicago, 776 F.2d 636, 1985 U.S. App. Lexis 23822 (7th Cir. 1985).
     Federal court will not interfere with residency ordinance where state has not ruled residency is a mandatory subject of bargaining. Kansas City FOP v. City of Kansas City, Kan., 620 F.Supp. 752 (D. Kan. 1984).
     Statutory preemption: New Jersey upholds anti-residency law, which prevents cities from enforcing their local residency regulations. Booth v. Twp. of Winslow, 193 N.J. Super. 637, 475 A.2d 644 (A.D. 1984).
     Illinois appellate court upholds Chicago's fire and police residency law. Fagiano v. Police Bd. of Chicago, 463 N.E.2d 845 (Ill.App. 1984), applying decision at 98 Ill.2d 277, 456 N.E.2d 27 (1983).
     Illinois appellate court upholds an under-500,000 inhabitants home rule residency requirement for public safety employees. Budka v. Bd. of Public Safety Cmsnrs., 120 Ill.App.3d 348, 458 N.E.2d 126, 1983 Ill.App. Lexis 2619, 75 Ill.Dec. 958 (App. 1st Dist. 1983). {N/R}
     Residency ordinance upheld in Indiana: Fletcher v. Town of Highland, 461 N.E.2d 147 (Ind.App. 1984).
     Hiring preference: City can constitutionally give preference points to members of their fire or police department and defeat non-resident candidates. Beccia v. City of Waterbury, 192 Conn. 127, 470 A.2d 1202 (1984).
     Arbitrator could find violation of city residency ordinance was not "just cause" for dismissal. City of Saginaw v. Saginaw Firefighters Assn., 343 N.W.2d 571 (Mich. App. 1984).
     Dual residences is not compliance with regulation; appellate court upholds termination of firefighter. Civil Serv. Cmsn. of Pittsburgh v. Parks, 471 A.2d 154 (Pa. Cmwlth. 1984).
     Marital rights: City could enforce residency law against a policewoman that married policeman who was exempt from new law, and lawfully lived outside the city. City of Denver v. Indus. Cmsn. of Colo., 666 P.2d 160 (Colo. App. 1983).
     Employee can have two residences without violating city residency law; domicile not an issue. Werner v. Dept. of Police, 435 So.2d 475 (La. App. 1983).
     Louisiana appellate court upholds residency rule for new employees, but distinguishes those who lived outside city before rule adopted. Smiley v. City of Winnfield Police, 438 So.2d 680 (La. App. 1983).
     Illinois court rejects firefighter's claim of city residence; spent too much time with suburban "estranged" wife. O'Boyle v. Personnel Bd. of Chicago, 456 N.E.2d 998 (Ill.App. 1983).
     Appellate court upholds residency law; not void for vagueness, not unenforceable because of statements of superiors. Eastman v. City of Madison, 342 N.W.2d 764 (Wis. App. 1983).
     Even though department excused others, city could still enforce residency requirements against employee who was repeatedly warned. City of Meadville v. Neff, 450 A.2d 1078 (Pa. Cmwlth. 1982).
     Union and city can agree not to enforce a residency requirement, but when agreement ends, those in non-compliance are subject to disciplinary actions. Murray v. City of Jennings, 639 S.W.2d 220 (Mo.App. 1982).
     Promotional preference residency law upheld. Gallagher v. Mayor of Irvington, 184 N.J. Super. 225, 445 A.2d 477 (N.J. Promotional preference residency law upheld. Gallagher v. Mayor of Irvington, 184 N.J. Super. 225, 445 A.2d 477 (N.J. Sup'r 1982); rev'd in part, 190 N.J. Super. 394, 463 A.2d 969, 1983 N.J. Super. Lexis 905 (1983).
     State labor commission requires city to bargain with union over residency issue. City of Boston and Boston Superior Officers Federation, Mass. Labor Rel. Cmsn. Case #MUP-4071, G.E.R.R. 953:18 (1981).
     Employee entitled to fair warning over residency deficiencies and allowed a reasonable time for compliance. City of Chicago and Chicago Firefighters L-2 IAFF, 81-2 ARB ¶ 8398, 1981-82 PBC (CCH) ¶ 45,399 (Kelliher, 1981).
     • ALR Annotation: Validity, Construction, and Application of Enactments Relating to Requirement of Residency Within or near Specified Governmental Unit as Condition of Continued Employment for Policemen or Firemen, 4 ALR 4th 380 (1981).
     Occasional surveillance of firefighter staying with family outside city not sufficient evidence to warrant termination where the employee denies a violation of residency rule. Choike v. City of Detroit, 290 N.W.2d 58 (Mich. App. 1980).
     Home rule cities may not supercede state law on residency. Uniformed Firefighters Association v. City of New York, 50 N.Y.2d 85, 405 N.E.2d 679 (1980).
     Louisiana appellate court rejects city's residency law as unrelated to departmental need; firefighter reinstated. White v. City of Winnfield Fire Dept., 384 So.2d 471 (La. App. 1980).
     Minnesota upholds municipal residency rules. Guttu v. City of East Grand Forks, 294 N.W.2d 735 (Minn. 1980).
     Unpublished residency ordinance not enforceable. Brown v. City of Meridan, 370 So.2d 1355 (Miss. 1979).
     Residency rule upheld in North Carolina. Maines v. City of Greensboro, 259 S.E.2d 334 (N.C. App. 1979).
     Illinois appellate court upholds residency rules for police officer and firefighters. Hoban v. Rochford, 73 Ill.App. 3d 671, 392 N.E.2d 88, 1979 Ill.App. Lexis 2967; 29 Ill.Dec. 531 (App. 1st Dist. 1979){N/R}; Harvey Firemen's Assn. v. City of Harvey, 389 N.E.2d 151 (Ill. 1979).
     Meaning of ten mile limit. Burke v. Chief of Police of Newton, 373 N.E.2d 949 (Mass. 1978).
     Neighborhood requirements must be reasonably drawn. Lanam v. Civil Serv. Cmsn. of Ukiah, 145 Cal.Rptr. 590 (App. 1978).
     Retroactivity of rules upheld. Doris v. Police Cmnsr. of Boston, 373 N.E.2d 944 (Mass. 1978).
     Military station not determinative of residency. Frazier v. Allen, 363 So.2d 542 (La. App. 1978).
     Preferences: Residency requirement does not authorize city to pass over a candidate on eligibility lists; out-of-state applicant can re-establish residency. Kerr v. Weisenberg, 410 N.Y.S.2d 351 (A.D. 1978).
     City residency ordinance cannot contravene state statutes. City of Atlanta v. Myers, 240 S.E.2d 60 (Ga. 1977).
     Adequate proof of non-residency shown. Nigro v. Bd. of Trustees, Vil. of Alden, 395 N.Y.S.2d 544 (A.D. 1977).
     Federal appeals court upholds city law, requiring non-resident employees to move within city limits. Andre v. Bd. of Trustees of Maywood, 561 F.2d 48 (7th Cir. 1977).
     Equal protection and laches discussed as defenses. Municipal Civil Serv. Cmsn. of Opelousas v. Myers, 348 So.2d 1334 (La. App. 1977).
     U.S. Supreme Court affirms Philadelphia residency rule in an unsigned order. McCarthy v. Philadelphia Civil Serv. Cmsn., 424 U.S. 645, 96 S.Ct. 1154 (1976), affirming 339 A.2d 634 (Pa. Cmwlth 1975); see also, Hunter v. Fraternal Order of Police, #75-846, 44 U.S.L.W. 3532 (cert. den. 1976).
     CETA employees have employment preference over non-resident firefighters who were laid off for economic reasons; seniority rights not applicable. Carritue v. Beame, 395 N.Y.S.2d 573 (Misc. 1976).
     Fifth circuit upholds continuing residency requirement; firefighters forced to move back into city. Wright v. City of Jackson, 506 F.2d 900 (5th Cir. 1975).
     Exemptions: New Jersey residency legislation, exempting firefighters, denies equal protection to other municipal employees. Trainor v. City of Newark, 137 N.J. Super. 570, 350 A.2d 83 (1975).
     Ohio municipalities may not impose a residency requirement retroactively. Fraternal Order of Police v. Hunter, 49 Ohio App.2d 185 (1975).
   
  New Jersey law outlawing residency requirements for firemen held constitutional; given retroactive effects. Smith v. City of Newark, 320 A.2d 212 (N.J. Super. 1974).
     Chicago Police Board could punish a residency violation; a confirming civil service rule was not needed. Manion v. Kreml, 131 Ill.App.2d 374, 264 N.E.2d 842, 1970 Ill.App. Lexis 1109 (App. 1st Dist. 1970).{N/R}
     Supreme Court recognizes the right of municipalities to condition public employment with continued residency in the city. Detroit Police Officers Assn. v. City of Detroit, 405 U.S. 950, 92 S.Ct. 1173 (1972). {N/R}

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