Illinois Gambling Act Restricts Casinos to Named Cities

Illinois casino and riverboat siting runs entirely through the Illinois Gambling Act, not local zoning codes. Section 7(c) requires that each owners license "specify the place where the casino shall operate or the riverboat shall operate and dock", the location is fixed into the state license itself. Subsection (e) authorizes up to 10 original riverboat licenses tied to specific waters: three on the Mississippi River (including East St. Louis and Alton home docks), one on the Illinois River at East Peoria or land-based in Peoria, one on the Des Plaines River in Will County, and four more at the Illinois Gaming Board's discretion.

Subsection (e-5), added by Public Act 101-31 in 2019, authorizes six more licenses pinned to specific places: Chicago, Danville, Waukegan, Rockford, a Cook County township cluster (Bloom, Bremen, Calumet, Rich, Thornton, or Worth), and unincorporated Williamson County near the Big Muddy River. Before the Board will consider any of these six, the host municipality or county board must certify it negotiated in good faith, agreed on a permanent and temporary location, agreed on revenue sharing, resolved "zoning, licensing, public health, or other issues," and passed a resolution or ordinance supporting the project after a public hearing.

Chicago's license also required a Board-commissioned feasibility study before applications could open. Gaming positions are capped by location: 4,000 for Chicago, 2,000 for the other named 2019 cities, 1,200 for Williamson County. Separately, subsection (j) bars the Board from issuing or renewing any dock license unless the municipality's or county's governing body has approved docking by majority vote, so local government keeps a veto even though it cannot independently authorize a casino.

There is no local application to file: a city cannot zone in a casino on its own initiative, and operating casino or riverboat gambling without a Board-issued owners license violates the Act's licensing requirements in Sections 6 and 7. The Illinois Gaming Board enforces the Act and can deny, suspend, or revoke a license; under subsection (e-20) it may revoke an owners license outright if the holder fails to begin conducting gambling within 15 months of the Board's approval.