Fritz Kaegi v. A.F. Moore & Associates, Inc., et al.

This Court previously examined Illinois’ property tax objection system and declared it a plain, speedy, and efficient process for taxpayers to obtain tax relief. Rosewell v. LaSalle Nat. Bank, 450 U.S. 503 (1981). Since Rosewell, the Illinois General Assembly further streamlined that process, requiring taxpayers to demonstrate only that their property was overvalued—regardless of the reason—without the need for burdensome litigation. Here, the Seventh Circuit upended that carefully considered statutory scheme, subverting the Illinois legislature’s intent to reform the tax objection process. The court disregarded the Tax Injunction Act and unilaterally expanded federal jurisdiction by permitting ordinary property tax objections to be heard by federal district courts, despite Illinois’ courts ability and obligation to hear such claims in the first instance. Accordingly, this case presents two questions: 1. Does the Seventh Circuit’s opinion in A.F. Moore v. Pappas continue the movement, begun in Hibbs v. Winn, 542 U.S. 88 (2004), to erode the vitality of the Tax Injunction Act and undermine congressional intent by further narrowing the Act’s once-broad jurisdictional bar to litigating state taxation matters in federal court when it concluded that Illinois trial courts, as courts of general jurisdiction with concurrent jurisdiction to hear federal constitutional claims, could not hear or adequately resolve property tax objections based on federal equal protection grounds?