State Farm v. The City of Chicago

City Department of Revenue sent a City employee a notice that he owed City $895 for damage to City police car that employee hit. Notice created actual controversy ripe for adjudication, because notice states employer will be notified, and his indebtedness can be publicized per FOIA and on City website, and is subject to wage garnishment or discharge. Exhaustion of remedies inapplicable, because notice does not state employee's right to administrative hearing to contest debt, thus did not initiate administrative proceeding.