Lawrence B. Lennon, et al, Plaintiffs-Appellants,
City of Carmel, Indiana, et al, Defendants-Appellees.
May 19, 2017
from the United States District Court for the Southern
District of Indiana, Indianapolis Division. No.
l:15-cv-02072-JMS-MJD - Jane E. Magnus-Stinson, Chief Judge.
Wood, Chief Judge, and Bauer and Posner, Circuit Judges.
people raise an astonishing variety of claims in the federal
courts of this country, the fact remains that there are
limits on the subject-matter jurisdiction of those courts.
This case implicates one of those limits: the federal
district courts are not authorized to sit in review of
state-court decisions, unless Congress has passed appropriate
legislation. This is so even if one or all parties would like
an answer from the federal court. As the district court here
recognized, nearly all of the case now before us runs afoul
of this jurisdictional rule. We affirm its dismissal of the
action, with some minor modifications.
plaintiffs in this case are motorists who were stopped by the
local police for traffic violations in the City of Carmel,
Indiana. Each of the plaintiffs was cited for violating
Carmel City Ordinance § 8-2, which (at that time)
adopted and incorporated the state of Indiana's traffic
regulations in lieu of reinventing the wheel. Some of the
plaintiffs admitted to the cited offense and paid a fine.
Some of the plaintiffs did not appear at a hearing and a
default judgment was entered against them. Others were
convicted of the offense at a bench trial. And the remaining
plaintiffs entered into deferral agreements under which they
paid a fine and avoided prosecution or conviction. Not one of
the plaintiffs appealed the citation or judgment, or
otherwise challenged the deferral agreements in Indiana's
acquiescence did not stem from a lack of access to the state
courts. A motorist unassociated with the current case
challenged his section 8-2 traffic citation in the Indiana
state courts and won relief when the Indiana Court of Appeals
held that the ordinance violated Indiana's Home Rule
laws. See Maraman v. City of Carmel, 47 N.E.3d 1218
(Ind.Ct.App. 2015), transfer denied, 48 N.E.3d 317 (Ind.
Maraman was decided, the plaintiffs in this case
filed an action in the federal district court against a
hodge-podge of local and state officials, including members
of Carmel's city council; its mayor, legal counsel, and
chief of police; the municipal court; a judge of that court;
and the superintendent of Indiana's Bureau of Motor
Vehicles (BMV). These defendants, plaintiffs asserted, had
violated 42 U.S.C. § 1983 by engaging in a wide-ranging
conspiracy to deprive them of their civil rights through
misuses of the Carmel traffic justice system. The complaint
alleged, among other things, that plaintiffs were given false
or limited information regarding their traffic infractions,
that the Carmel Police Department wrongfully ticketed
motorists on Interstate 465, that the City of Carmel had a
policy of improperly ticketing motorists for non-moving
violations, that the deferral agreements were misleading,
that plaintiffs were illegally prosecuted and did not receive
due process during their trials, that they were deprived of
the right to be judged by a tribunal untainted by a financial
interest, that the defendants knew that the cost to challenge
the tickets exceeded the cost of paying the tickets, and that
the defendants forwarded inaccurate information about
plaintiffs' traffic violations and judgments to the BMV.
For good measure, the plaintiffs also included a state-law
claim for unjust enrichment against the City of Carmel.
of relief, plaintiffs sought damages and equitable relief,
including the expungement of their section 8-2 violations
from their driving records and a stay against any action the
BMV might take in response to the judgments. In response to
the defendants' motion to dismiss, the district court
tossed the case on several grounds: certain plaintiffs lacked
standing; the Rooker-Feldman doctrine deprived the
court of jurisdiction to hear most of the claims for relief;
plaintiffs had abandoned various other claims; and the claims
that survived the juris-dictional bars failed to state a
claim upon which relief could be granted. The plaintiffs now
challenge all of those rulings.
first step in any matter is always to ensure that both the
district court and this court have jurisdiction over the
case. See Young v. Murphy, 90 F.3d 1225, 1230 (7th
Cir. 1996). One situation raising a red flag occurs when a
section 1983 complainant appears to be seeking review of a
state-court judgment. Id. at 1231. That is a power
that has not, in general, been conferred on the lower federal
courts; only the Supreme Court has it, and its review is
limited to questions of federal law. See 28 U.S.C. §
1257; Skinner v. Switzer, 562 U.S. 521, 532 (2011).
Federal courts do not have the power to hear "cases
brought by state-court losers complaining of injuries caused
by state-court judgments rendered before the district
proceedings commenced and inviting district court review and
rejection of those judgments." Exxon Mobil Corp. v.
Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005). This
principle is commonly referred to as the
"Rooker-Feldman doctrine, " after the
cases that first recognized it: Rooker v. Fidelity Trust
Co., 263 U.S. 413 (1923), and District of Columbia
Court of Appeals v. Feldman, 460 U.S. 462 (1983).
Rooker-Feldman bar is jurisdictional; violations of
it cannot be waived and thus preclude a court from
considering the merits of the claim. See Long v.
Shorebank Dev. Corp., 182 F.3d 548, 555 (7th Cir. 1999)
(noting that the applicability of Rooker-Feldman
must be determined before considering the arguments). There
is no exception for egregious error. Kelley v. Med-1
Sols., LLC, 548 F.3d 600, 603 (7th Cir. 2008).
"[L]itigants who feel a state proceeding has violated
their constitutional rights must appeal that decision through
their state courts and thence to the Supreme Court."
Young, 90 F.3d at 1230.
already said enough to show why Rooker-Feldman
applies here to the claims the district court labeled the
"Judgment/Adjudication Claims." The heart of the
plaintiffs' grievances is that they were cited in state
traffic court for violations of an ordinance that the Indiana
courts later held to be invalid (albeit on home-rule grounds,
not because of anything particular to the traffic rules).
Plaintiffs claim to have been injured by paying fines and
through the inclusion of "invalid" traffic
citations on their driving records; those citations in turn
have allegedly increased their insurance rates. All of the
cases, with the exception of those resting on deferral
agreements, fall squarely within the scope of
Rooker-Feldman: the plaintiffs lost in state court,
their injuries flowed from the state-court judgments, the
injuries occurred prior to the federal proceedings, and they