Lennon v. City of Carmel, No. 16-3836 (7th Cir. 2017)Annotate this Case
Plaintiffs were cited for violating Carmel City Ordinance 8-2, which incorporated Indiana’s traffic regulations. Some paid a fine. Some had a default judgment entered against them. Some were convicted; others entered into deferral agreements. None appealed or otherwise challenged the outcome in Indiana’s courts. In a separate case, the Indiana Court of Appeals held that the ordinance violated Indiana’s Home Rule laws. Plaintiffs then filed suit under 42 U.S.C. 1983, alleging conspiracy to deprive them of their civil rights through misuses of the traffic justice system. The district court dismissed, finding that certain plaintiffs lacked standing; the Rooker-Feldman doctrine deprived the court of jurisdiction to hear most of the claims; plaintiffs had abandoned various other claims; and the other claims failed to state a claim upon which relief could be granted. The Seventh Circuit affirmed, citing the Rooker-Feldman doctrine with respect to plaintiffs who admitted guilt, were convicted, or had default judgments. Federal district courts are not authorized to review state-court decisions unless Congress has passed appropriate legislation. The “deferral agreement” plaintiffs had no constitutional claims. Those alleging injuries arising from traffic stops that preceded and were unrelated to the traffic judgments described damages too speculative or that cannot be separated from the state-court traffic judgment.