James Garry and Thomas Thompson v. John Geils, Individually and as President of the Village of Bensenville, Richard Weber, Peggy Walberg, Richard Reimer, Joseph Krass, Robert Strandt, Barbara Wanzung, Individually and as Trustees of the Village of Bensenville
Docket: 95-1452
Court: Court of Appeals for the Seventh Circuit; April 22, 1996; Federal Appellate Court
In May 1994, the Village of Bensenville obtained a state court order to condemn part of property owned by James Garry and leased to Thomas Thompson for Thompson's rental business. Garry and Thompson filed a federal 1983 action against the Village's President and Trustees, alleging political retaliation for their support of losing candidates from the Bensenville Home Town Party in the 1991 Village Board elections. The district court dismissed their case, citing res judicata. However, the Court of Appeals found that the Rooker-Feldman doctrine was the appropriate framework, as the plaintiffs were effectively claiming injury caused by the state court's decision. The appellate court affirmed the dismissal, noting that the defendants had influenced the relocation of a drainage ditch proposed by the Illinois Department of Transportation, which significantly impacted the Garry property by rendering a portion unusable and obstructing customer access to Thompson’s rental business.
Plaintiffs allege that defendants forced a property shift as retaliation for their support of the Home Town Party during the 1991 elections. After unsuccessful negotiations, the Village initiated a condemnation action on November 17, 1992, to acquire part of the Garry property based on revised ditch plans. Following a hearing on March 17, 1994, the Circuit Court of DuPage County confirmed the Village's authority to use eminent domain, determined the Garry property was subject to this power, and set preliminary just compensation at $71,000 for necessary easements. By May 9, 1994, this compensation was deposited, and title to the easements was vested in the Village.
On July 14, 1994, plaintiffs filed a case under 42 U.S.C. § 1983, claiming First and Fourteenth Amendment violations due to the defendants moving the ditch site to punish them for their political stance. They sought damages and injunctions against further property use by defendants. The district court dismissed the case, citing res judicata, and later denied a motion to reconsider, asserting plaintiffs could have raised their constitutional claims earlier.
The defendants invoked the Rooker-Feldman doctrine, which limits federal court jurisdiction over state court decisions, arguing that neither the district court nor the appellate court had the authority to hear the case. This doctrine maintains that federal courts cannot review state court judgments, a principle established in *Rooker v. Fidelity Trust Co.* and *District of Columbia Court of Appeals v. Feldman*. The Supreme Court noted that only it has the power to modify or reverse state court judgments.
Lower federal courts lack jurisdiction to review state court decisions, as established by the Rooker-Feldman doctrine. This principle asserts that such federal courts cannot engage in appellate review of state determinations. The distinction between Rooker-Feldman and res judicata is critical; Rooker-Feldman must be addressed first, as it can preclude consideration of res judicata claims. In instances where the Rooker-Feldman doctrine applies, federal courts do not have jurisdiction to consider other defenses, including res judicata.
The applicability of Rooker-Feldman hinges on whether the injury claimed by the federal plaintiff is a direct result of the state court judgment. If the injury stems from the judgment, Rooker-Feldman bars federal jurisdiction. Conversely, if the injury is separate and not intertwined with the state judgment, res judicata may be applicable, but Rooker-Feldman would not apply. Historical cases highlight that even if a state court decision is viewed as wrongful, federal courts cannot reverse or modify it based on constitutional claims.
Federal district courts lack jurisdiction to hear cases where a plaintiff claims injury from a state court's decision, with the only recourse being an appeal to the Supreme Court after a final state judgment, as established by the Rooker-Feldman doctrine. This principle was further elucidated in the GASH case, which distinguished between injuries stemming directly from state court judgments and those arising from unaddressed prior injuries. The court noted that GASH's claims were barred by Rooker-Feldman because they were inherently linked to an adverse state court judgment regarding a foreclosure.
The distinction between Rooker-Feldman and res judicata has been recognized in this circuit, particularly in instances where the plaintiff's status in state court influences the applicable legal doctrine. If the federal plaintiff was a plaintiff in state court, res judicata applies; if a defendant, Rooker-Feldman does. This framework was articulated in Homola and Nesses but is not intended as a strict rule, as both plaintiffs in Rooker and Feldman were also plaintiffs in their respective state courts. Instead, the guideline serves as a general principle to determine jurisdictional issues based on the plaintiff's role in the preceding state judgment, aligning with the source-of-injury standard.
A plaintiff in state court typically alleges an injury caused by a defendant, which may lead to a subsequent federal action if no remedy is obtained from the state judgment. In such cases, the federal injury is distinct from the state court decision, making res judicata potentially applicable but not Rooker-Feldman. Conversely, a federal claim by a former state court defendant usually arises from an injury due to a "wrongful" state judgment, which Rooker-Feldman prohibits federal courts from adjudicating, thus avoiding res judicata. Most Rooker-Feldman cases involve federal plaintiffs who were defendants in prior state actions, although exceptions exist, particularly regarding declaratory judgment suits where the losing plaintiff may be barred from federal court.
An example is Feldman, where the Supreme Court ruled that a federal district court lacked jurisdiction over a case following an unsuccessful state court petition. The distinction between Rooker-Feldman and res judicata is pivotal; in this case, the district court lacked jurisdiction under Rooker-Feldman because the plaintiffs' claims stemmed from a state judgment condemning their property. Their alleged injury arose only after the condemnation, indicating that their grievance was against the state court's actions. The state court had determined that the eminent domain power was properly exercised, and any constitutional challenge should have been pursued through the Illinois condemnation process, ultimately to the U.S. Supreme Court if necessary. Past decisions affirm that challenges to the constitutionality of condemnation actions should be raised in state court, regardless of potential waiver of claims. This procedural context reinforces the lack of jurisdiction under Rooker-Feldman in this instance.
A plaintiff who fails to raise claims in state court may lose the right to seek federal court review of the state court's decision. This principle is supported by the Rooker-Feldman doctrine, which holds that claims 'inextricably intertwined' with state court judgments do not permit federal district court jurisdiction, as they effectively seek to review those judgments. The court found that the plaintiffs' claim of political retaliation, although not presented in the state condemnation action, is deeply connected to it, thus falling under the Rooker-Feldman doctrine. Similar to the case of Wright v. Tackett, where attempts to challenge a state court judgment by framing the complaint as a civil rights action were barred, the plaintiffs cannot use a damages claim to circumvent this principle. The plaintiffs argued that their damages claim should not be subject to Rooker-Feldman, but no legal authority supports this position; previous rulings have consistently applied the doctrine to damages claims. Consequently, the district court's dismissal of the plaintiffs' claim is affirmed, specifically on the grounds of lack of federal jurisdiction under the Rooker-Feldman doctrine.
The plaintiffs' political retaliation claim hinges on comments made by Village Engineer John A. Bruszewski, who indicated that the ditch site was relocated at the Village Board's request. However, Bruszewski's testimony lacks clarity regarding the original ditch location and suggests that another property, Road Pilot, influenced the relocation. The court does not possess jurisdiction to evaluate the merits of the plaintiffs' claim, and the evidence presented appears insufficient. After their claim was rejected, the plaintiffs sought to return to state court to file a cross petition and a third-party complaint, but their motions were denied, and they did not appeal this decision.
The defendants did not raise the Rooker-Feldman doctrine in their motion to dismiss; instead, they focused on waiver, federal abstention, res judicata, and legislative immunity. The Rooker-Feldman doctrine was only invoked after the dismissal was granted, in response to the plaintiffs' motion for reconsideration. Exceptions exist for collateral review of state court judgments, such as habeas corpus under 28 U.S.C. § 2241.
The Rooker-Feldman doctrine asserts that state court decisions, even if erroneous, are not constitutional violations actionable in federal court. Federal jurisdiction can exist if the injury alleged is due to nonjudicial actions of a state court rather than judicial proceedings. This distinction was highlighted in cases like Homola and Nelson v. Murphy, which indicate that challenges to state court administrative actions can be heard in federal court.
Rooker-Feldman is distinct from res judicata; the former is a federal doctrine requiring no reference to state law, while the latter requires examination of state law to determine whether a prior judgment precludes the federal claims. Res judicata also considers whether the party had a fair opportunity to pursue their claim in state court, a factor not present in Rooker-Feldman.
Res judicata is an affirmative defense that can be waived, while Rooker-Feldman is a jurisdictional doctrine that cannot be waived. Rooker-Feldman applies to cases where a defendant in state court seeks to overturn a remedial order, constituting a collateral attack on a state court judgment, whereas res judicata bars a plaintiff from relitigating a decided claim. Federal cases demonstrate that Rooker-Feldman jurisdiction is not available even if the federal plaintiff had a prior role as both a plaintiff and defendant in state court, as illustrated in Landers Seed and Homola. In Illinois, challenges to the propriety of condemnation proceedings must be made through a traverse or motion to dismiss during the preliminary stage. The plaintiffs failed to challenge the constitutionality of the condemnation in a timely manner, as they did not seek a stay or appeal the court's order within the required 30-day period. Claims that their constitutional arguments would not be heard in Illinois are contradicted by case law recognizing the availability of immediate interlocutory appeals for such claims. The courts of Illinois are expected to uphold the Constitution, and the plaintiffs' issues stem from their own procedural missteps rather than a failure of the Illinois judicial process.
