Pinkston v. City of Chicago
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The Municipal Code of Chicago included provisions concerning public parking, including parking meters. The fine for exceeding the time purchased at a parking meter differs depending on whether the violation occurs in the “central business district” or the “non-central business district.” At the time of the alleged violation, failure to comply with the parking meter regulations in the central business district resulted in a $65 fine. A $50 fine applied to similar violations outside the central business district.
Pinkston filed a class-action, alleging that Chicago had engaged in the routine practice of improperly issuing central business district tickets for parking meter violations. The circuit court dismissed for failure to exhaust administrative remedies before the Chicago Department of Administrative Hearings and voluntarily paying his fine. The appellate court reversed. The Illinois Supreme Court reinstated the dismissal. The underlying issue—whether Pinkston received an improper parking ticket—is routinely handled at the administrative level; an aggrieved party cannot circumvent administrative remedies “by a class action for declaratory judgment, injunction or other relief.”
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