Michelle Veasey, the former owner of a sports bar in Rock Island, Illinois, sued four local officials after the city revoked her establishment's liquor license. The revocation followed administrative complaints alleging violations of city ordinances regarding loitering and unruly conduct, as well as a later incident involving a minor on the premises. Veasey alleged that the officials discriminated against her based on race, withheld evidence, and violated her due process rights. The district court granted summary judgment for the defendants, ruling that three of the officials were immune from suit and that the fourth official's actions did not violate the Constitution. Veasey appealed, challenging the immunity determinations and the sufficiency of the evidence regarding due process and racial discrimination.
The Seventh Circuit affirmed the district court's decision, relying heavily on established immunity doctrines. The court held that Mike Thoms, the liquor control commissioner, was protected by absolute quasi-judicial immunity because he acted in a judicial capacity when presiding over the license revocation hearings. This immunity applies even if the official acts maliciously, provided the function is judicial in nature. Similarly, the court found that city attorneys David Morrison and Hector Lareau were entitled to absolute quasi-prosecutorial immunity. They were acting in a prosecutorial capacity when they signed and filed the administrative complaints alleging ordinance violations. Regarding Police Chief Richard Landi, the court affirmed that Veasey failed to meet her burden of proof. The record did not contain evidence from which a reasonable jury could infer that Landi violated her due process rights or engaged in racial discrimination. The court also addressed Veasey's argument that the district judge should have been disqualified due to a conflict of interest involving her marriage to a state court judge. The appellate court applied an objective standard, concluding that a reasonable observer would not question the federal judge's impartiality based solely on her marriage to a state court judge working in the same county.
The decision reinforces the broad scope of absolute immunity for local officials performing quasi-judicial and prosecutorial functions in the Seventh Circuit. It signals that plaintiffs challenging liquor license revocations must overcome high immunity barriers before reaching the merits of their due process or discrimination claims. The ruling leaves the underlying factual disputes regarding the license revocation unaddressed, as the immunity and evidentiary standards precluded the claims from proceeding to a jury. No remand instructions were issued as the judgment was affirmed.
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