Capra v. Cook County Board of Review
733 F.3d 705
| 7th Cir. | 2013Background
- In 2009 news reports suggested Illinois Rep. Paul Froehlich arranged property-tax reductions for constituents in exchange for political support; two taxpayers (Capra and Satkar Hospitality) received reductions and later had them rescinded after Board of Review rehearings.
- Plaintiffs sued the Cook County Board of Review and individual commissioners/staff under 42 U.S.C. § 1983 alleging equal protection, due process, and First Amendment retaliation violations.
- District courts dismissed the individual defendants based on quasi-judicial absolute immunity but denied absolute immunity to the Board itself.
- Appeals challenged individual immunity rulings and the Board’s liability; the Seventh Circuit consolidated analysis and reviewed immunity and abstention issues.
- The Seventh Circuit affirmed absolute quasi-judicial immunity for individual board members/staff, held municipalities are not entitled to absolute immunity, but dismissed the § 1983 damage claims against the Board without prejudice under the comity doctrine of Fair Assessment v. McNary because adequate state remedies exist.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether individual Board members/staff are immune from § 1983 damages | Plaintiffs: defendants acted discriminatorily and unlawfully; immunity should not apply to shield unconstitutional conduct | Defendants: quasi-judicial absolute immunity applies to adjudicatory acts of Board members/staff | Held: Individual defendants entitled to quasi-judicial absolute immunity (affirmed) |
| Whether the Cook County Board of Review (municipal entity) has absolute quasi-judicial immunity | Plaintiffs: Board liable under § 1983 for unconstitutional policies/practices | Board: same functional immunity as its members; alternatively Eleventh Amendment sovereign immunity | Held: Municipal entity not entitled to absolute immunity under Monell; Eleventh Amendment not applicable here |
| Whether federal courts may hear § 1983 damage claims challenging state/local tax decisions | Plaintiffs: federal forum appropriate because constitutional rights violated and state remedies are inadequate or biased | Defendants/amicus: Fair Assessment comity doctrine bars federal damages suits where adequate state remedies exist | Held: Fair Assessment requires abstention — damages claims against Board dismissed without prejudice because Illinois remedies are plain, adequate, and complete |
| Adequacy of plaintiffs’ pleadings for a class-of-one equal protection claim | Capra: identified class-of-one theory sufficiently at pleading stage without naming specific comparators | Board: complaint failed to identify similarly situated comparators | Held: District court erred to require specific comparators at pleading stage; allegations were adequate under Rule 8 and Geinosky |
Key Cases Cited
- Fair Assessment in Real Estate Ass’n v. McNary, 454 U.S. 100 (1981) (comity doctrine bars federal § 1983 damages suits challenging state/local tax systems when adequate state remedies exist)
- Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipalities are subject to suit under § 1983 and are not entitled to absolute immunity)
- Heyde v. Pittenger, 633 F.3d 512 (7th Cir. 2011) (members of a county board of review performing quasi-judicial functions entitled to absolute immunity; applied Fair Assessment to dismiss claims against board)
- Butz v. Economou, 438 U.S. 478 (1978) (framework for absolute immunity for officials performing functions comparable to judges)
- Rosewell v. LaSalle Nat’l Bank, 450 U.S. 503 (1981) (state remedies are "plain, speedy and efficient" for Tax Injunction Act/Fair Assessment purposes if they provide full hearing and judicial determination)
- Geinosky v. City of Chicago, 675 F.3d 743 (7th Cir. 2012) (pleading standards do not require identification of specific comparators in a class-of-one equal protection complaint)