Vargas v. Cook County Sheriff's Merit Board, No. 19-1686 (7th Cir. 2020)
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The plaintiffs, current and former Cook County sheriff’s deputies and correctional officers, were disciplined for violating various departmental policies and rules. Seven of the eight plaintiffs were fired; the remaining officer was suspended. They sought to represent a class of officers who were disciplined in 2013-2016. The complaint under 42 U.S.C. 1983 alleged deprivations of due process based on a defect in the composition of the Merit Board: at the time of the challenged disciplinary decisions, certain Board members held their appointments in violation of Illinois law. They also alleged that Sheriff Dart and his General Counsel assumed control of the Board through political means and pressured its members to make decisions contrary to Illinois law.
The Seventh Circuit affirmed the dismissal of the claims. A violation of state law is not a federal due-process violation, so the defect in the Board’s membership is not a basis for a federal constitutional claim. The allegations of biased decision-making suggest only that the plaintiffs may have suffered a random and unauthorized deprivation of their property interest in public employment. An injury of that type is not a violation of due process if the state offers adequate postdeprivation remedies. Illinois provides constitutionally adequate postdeprivation remedies for aggrieved public employees.
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