## Facts

- Chicago adopted an administrative, civil system for adjudicating parking violations under its municipal code.
- Ticket recipients could either pay a civil penalty (capped at $100) or contest the ticket in writing or in person before an administrative hearing officer.
- Hearings were conducted by part-time hearing officers who were private attorneys hired by, and removable at will by, the City’s director of revenue.
- The issuing officer typically did not appear; the ticket functioned as an affidavit and prima facie evidence of the violation, subject to rebuttal by the motorist’s testimony and other evidence.
- Hearing officers could consider documentary evidence, subpoena witnesses, and were instructed to conduct a “searching” cross-examination of the ticket recipient.
- After an adverse administrative decision, a motorist could seek judicial review in state circuit court but had to pay a filing fee of about $200.
- A class of ticket recipients sued, alleging the procedures violated due process under the U.S. and Illinois Constitutions; the district court dismissed for failure to state a claim.

## Issues

1. Whether federal jurisdiction was barred by the Rooker–Feldman doctrine because the suit allegedly collaterally attacked prior parking-liability determinations.
2. Whether the administrative parking adjudication procedures violated Fourteenth Amendment procedural due process.
3. Whether the same procedures violated due process under the Illinois Constitution.

## Decision

- The court held Rooker–Feldman did not apply because the challenged determinations were administrative, not state-court judicial judgments.
- The court affirmed dismissal of the federal due process claim, concluding the procedures provided constitutionally adequate process for low-stakes, high-volume parking adjudications.
- The court affirmed dismissal of the Illinois constitutional claim, treating the state due process analysis as aligned with the federal analysis on these facts.

## Legal Principles

- Rooker–Feldman is confined to federal district-court review of state-court judgments and does not bar challenges to state or municipal administrative decisions.
- Procedural due process is context dependent; in high-volume, low-penalty regimes, streamlined administrative procedures may be sufficient when they provide notice and a meaningful opportunity to be heard.
- Due process does not necessarily require live testimony from the ticketing officer when written evidence (such as an affidavit-like ticket) is rebuttable and the recipient can present evidence.
- A decision-maker is not unconstitutionally biased absent a sufficiently direct personal or institutional financial stake in outcomes; at-will removal and general governmental revenue interests, without outcome-based compensation, are typically insufficient.
- The Constitution does not guarantee that judicial review will be economically attractive relative to the amount in controversy; filing fees exceeding the fine do not, by themselves, establish a due process violation when an adequate initial hearing is available.

## Conclusion

The Seventh Circuit held that federal courts could hear a procedural challenge to Chicago’s administrative parking system because Rooker–Feldman did not extend to administrative decisions, and it upheld the system against federal and Illinois due process attacks, emphasizing that the Constitution permits simplified procedures for mass, low-dollar adjudication.


Van Harken v. City of Chicago, 103 F.3d 1346 (7th Cir. 1997)