Dibble v. Quinn

Dist. Ct. did not err in dismissing on qualified immunity grounds plaintiffs’ section 1983 actions alleging that enactment of Public Act 97-18, which shortened plaintiffs’ six-year terms as Workers’ Compensation arbitrators, deprived them of their property interests in their jobs without due process. Legislature, having previously created plaintiffs’ six-year terms in their positions, is not precluded from altering or even eliminating plaintiffs’ entitlement to full six-year term in their positions. Ct. rejected plaintiffs’ proposed exception to legislative enactment rule that would allow court to examine legislators’ motivation for altering plaintiffs’ property interest in their jobs and further found that process for Legislature’s enactment of Public Act 97-19 provided plaintiffs with sufficient due process. Moreover, plaintiffs failed to demonstrate any clearly established right that was violated by Legislature prematurely ending their six-year terms as arbitrators.