Santana v. Cook County Board of Review

Dist. Ct. did not err in dismissing for failure to state valid claim, plaintiff's section 1983 and civil RICO actions alleging that defendants-Cook County Bd. of Review and its members violated plaintiff's due process and First Amendment rights by red-flagging plaintiff's clients for unfavorable treatment on their property tax appeals and defaming him with respect to his business as property tax consultant, as well as running "pay for play" racketeering enterprise that sought to extort campaign contributions and consulting services from plaintiff. As to his due process claims, plaintiff failed to allege that his work as consultant was constitutionally protected property interest. Moreover, with respect to plaintiff's deprivation of protected liberty interest claim arising out of defendants' alleged defamation of his reputation under "stigma plus" theory, plaintiff failed to allege that defendants altered any right or status that was recognized by state law. Ct. also observed with respect to plaintiff's First Amendment and civil RICO claims that plaintiff failed to allege how defendants had been able to identify which tax appeals had been filed by plaintiff's clients.