Lombard v. West Chicago Park Commissioners

Background

A group of property owners objected to a local charge placed on strips of land along a wide boulevard that had been improved and decorated as a park. The owners said the original ordinance authorizing the charge had been declared void and that the legislature only authorized the assessment after the work was done. They argued the charge violated the Fourteenth Amendment’s promises of fair treatment and due process.

Reasoning

The Court focused on whether the state courts’ decision raised a federal constitutional question. It explained that whether an assessing ordinance actually existed or was made effective later was a matter of state law. The justices said the state courts had the final word on state-law issues about the ordinance and the amount of benefit, and that deciding those state-law questions did not by itself show a federal due-process or equal-protection violation. The opinion relied on earlier decisions showing federal review does not extend to every inconsistently reasoned state ruling.

Real world impact

The Supreme Court affirmed the state-court judgment and let the local charge stand. That means property owners challenging similar local assessments will usually need to prevail under state law first, because the federal Constitution is not violated merely because a state court interprets its own laws differently at different times. Municipalities may therefore enforce assessments authorized under state procedures as the state courts interpret them.