Dist. Ct. did not err in dismissing for failure to state viable cause of action plaintiffs-former Sheriff’s Deputies’ section 1983 action alleging that defendants-Sheriff and Merit Board deprived them of due process by: (1) terminating them for disciplinary reasons at time when certain Board members held their appointments in violation of Illinois law; and (2) Sheriff pressuring Board members to make decisions contrary to Illinois law. Violation of state law is not basis for federal due process claim, such that defect in Board’s membership is not basis for federal constitutional claim. Moreover, plaintiffs’ allegations of biased decision-making suggest only that plaintiffs may have suffered random and unauthorized deprivation of their property interest in public employment. As such, plaintiffs’ injuries cannot form basis of federal due process claim where, as here, Illinois state courts offer adequate post-deprivation remedies.
Federal 7th Circuit Court
Civil Court
Due Process