Smalis v. Allegheny County Board of Property Assessment, 632 F. App'x 78

Ernest Smalis owns commercial property in Pittsburgh and was incarcerated from 1999 until early 2010.
Tax assessment notices for 2000–2009 were mailed to his former address rather than his prison address; Smalis alleges constitutional violations from lack of notice.
Smalis challenged the assessments before the Allegheny County BPAAR and then sought a nunc pro tunc appeal in the Allegheny County Court of Common Pleas; the petition was denied for lack of prompt action.
The Pennsylvania Commonwealth Court affirmed the denial on the ground that Smalis’ nearly four-month delay showed lack of reasonable diligence.
After the Pennsylvania Supreme Court denied review, Smalis filed a pro se federal civil-rights suit asking for relief to allow appeals of the assessments and to stay any tax sale.
The District Court dismissed the federal complaint for lack of subject-matter jurisdiction under the Tax Injunction Act (TIA); Smalis appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Tax Injunction Act bars federal-court relief of Smalis’s challenge to local tax assessments	Smalis contends his due-process and equal-protection rights were violated by lack of notice and seeks federal relief to permit appeals and stay tax sale	Defendants argue federal courts lack jurisdiction under the TIA because state courts provide an adequate remedy and Smalis already pursued state remedies	TIA bars federal jurisdiction; dismissal affirmed because Smalis had access to and received meaningful review in state courts
Whether the inadequacy of state relief (because state courts denied nunc pro tunc relief) permits federal jurisdiction despite the TIA	Smalis argues that denial of nunc pro tunc relief deprived him of meaningful remedy so federal court should hear the claim	Defendants argue that availability and opportunity for review—not a favorable outcome—satisfies the TIA; state process was available and used	Court held that denial based on Smalis’s lack of diligence does not render the state remedy inadequate; TIA still bars federal jurisdiction

Batchelor v. Rose Tree Media Sch. Dist., 759 F.3d 266 (3d Cir. 2014) (standard of plenary review for jurisdictional dismissals)
Berne Corp. v. Gov’t of the V.I., 570 F.3d 130 (3d Cir. 2009) (statement of the Tax Injunction Act’s scope)
Gass v. County of Allegheny, Pa., 371 F.3d 134 (3d Cir. 2004) (state courts need only provide access and meaningful review under the TIA)