In December 2008, the 1851 Center issued a legal notice to the Toledo City Council and the Toledo Planning Commission advising that, if the City passed an ordinance applying “Minimum School Facilities Requirements” to private schools, the 1851 Center would pursue litigation. The requirements would have unconstitutionally restricted the growth, facilities, and curricula of existing Toledo private and charter schools. As a result, the City Council and the Planning Commission dropped efforts to pass the ordinance.