819 F. Supp. 2d 727
N.D. Ill.2011Background
- Satkar Hospitality owns a Schaumburg hotel and challenged its 2007 property tax assessment, which the Board of Review lowered, allegedly yielding $40,000 in annual tax savings.
- In 2009, media reports accused a state lawmaker of engineering favorable Board of Review results for constituents in exchange for campaign contributions, including Satkar’s contributions.
- After the media coverage, the Board allegedly summoned Satkar in June 2009 to discuss the appeal, but focused questions on Satkar’s relationship with the lawmaker rather than the property valuation.
- Following the June 2009 hearing, the Board purportedly rescinded the previously granted tax reduction, attributing the reversal to the Satkar–lawmaker relationship rather than merits.
- Satkar alleges selective treatment of similarly situated owners with no Froehlich ties, and that the revised assessment did not reflect the property's true value.
- Satkar pursued an appeal to PTAB, but alleges the Board red-flagged the matter, causing undue delay; they also allege another later assessment denial was retaliatory and improper.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Absolute/qualified immunity for Board actors | Board members acted in an adjudicative capacity harming due process and equal protection claims. | Board members/deputies are absolutely/qualifiedly immune for adjudicative actions. | Board individual defendants are dismissed; Board itself retains claims against it. |
| Rooker-Feldman applicability | State administrative action affected federal rights; challenge should proceed in federal court. | Rooker-Feldman bars relief because state judgments were involved. | Rooker-Feldman not invoked; federal review of state administrative action permitted. |
| Sufficiency of due process, equal protection, and First Amendment claims | Alleged retaliatory action violated procedural/due process and deprived First Amendment rights; equal protection class-of-one claim asserted. | Claims are inadequately pleaded and lack rational basis or state-process flaws. | Procedural and substantive due process and First Amendment retaliation claims plausibly stated; equal protection theory discussed but not resolved at this stage. |
| Supplemental jurisdiction over Illinois Review defamation claims | State law defamation/false light arise from same facts as federal claims; should be heard together. | Claims are novel state-law issues requiring separate consideration. | Court retains supplemental jurisdiction; declines to dismiss state-law claims against Illinois Review defendants. |
Key Cases Cited
- Heyde v. Pittenger, 633 F.3d 512 (7th Cir. 2011) (absolute quasi-judicial immunity for adjudicative functions)
- Kincaid v. Vail, 969 F.2d 594 (7th Cir. 1992) (clerks have absolute immunity for non-ministerial adjudicative actions)
- Burns v. Reed, 500 U.S. 478 (Supreme Court, 1991) (immunity protects judicial process from harassment)
- Engquist v. Oregon Dept. of Agric., 553 U.S. 591 (U.S. 2008) (class-of-one claims limited by public employee interactions and discretionary decisions)
- Avila v. Pappas, 591 F.3d 552 (7th Cir. 2010) ( Engquist exceptions discussed for class-of-one claims)
- Buckley v. Valeo, 424 U.S. 1 (Supreme Court, 1976) (political contributions protected as speech)
- Palka v. Shelton, 623 F.3d 447 (7th Cir. 2010) (due process pleading requirements and property interest considerations)
- Brooks v. Ross, 578 F.3d 574 (7th Cir. 2009) (pleading standards for federal civil claims)
- Hemmer v. Indiana State Bd. of Animal Health, 532 F.3d 610 (7th Cir. 2008) (Rooker-Feldman applicability to state agency decisions)