William Jefferson & Co., Inc. v. Board of Assessment and Appeal

William Jefferson & Co., Inc. (“William Jefferson”) lost a state administrative appeal in which William Jefferson challenged the Orange County Tax Assessor’s (“Assessor”) valuation of a parcel of real property. William Jefferson then filed suit in federal district court, alleging that its procedural due process rights were violated in the course of the administrative appeal hearing. We affirm the district court’s conclusion that the state administrative appeal did not deny William Jefferson procedural due process. In a separate memorandum disposition filed concurrently with this opinion, we affirm the lower court’s grant of the agency’s motion for a protective order and its denial of class certification.

I

William Jefferson owns a parcel of real property located in Orange County, California. William Jefferson disputed the Assessor’s valuation of that property and assessment of state property taxes. William Jefferson appealed the Assessor’s determination to the Assessment Appeals Board for Orange County (“Board”). The Board denied, on statute of limitations grounds, William Jefferson’s administrative appeal. The merits of the Board’s decision are not relevant here.

The…