Capra v. Cook County Bd. of Review

Dist. Ct. properly granted motion by defendants-members of Cook County Bd. of Review to dismiss on grounds of quasi-judicial immunity plaintiffs-taxpayers’ section 1983 actions alleging that defendants deprived them of their due process and equal protection rights, when defendants voted to reverse their prior reduction of plaintiffs’ property taxes based on newspaper reports that plaintiffs had allegedly obtained said reductions after giving campaign contributions and political support to local politician. Under Heyde, individual property tax board members were entitled to absolute immunity based on their quasi-judicial functions. Moreover, while defendant-Bd. itself was not entitled to such immunity, plaintiff’s lawsuit could not proceed in instant federal forum under Fair Assessment in Real Estate Ass’n, 454 US 100, since Dist. Ct. was required to abstain in lawsuits seeking damages under actions that challenge state and local tax collections, where, as here, plaintiff had adequate state remedy in terms of appeal procedure through PTAB.