Commonwealth Plaza Condominium Ass'n v. City of Chicago
693 F.3d 743
7th Cir.2012Background
- Plaintiffs challenged a Chicago zoning change IPD 1019 after the city rezoned land near Saint Joseph Hospital.
- Plaintiffs owned property within 250 feet and participated in hearings, then sued in state court alleging due process violations.
- Illinois Appellate Court held a home-rule city may violate its own ordinances without constitutionally invalidating IPD 1019.
- Illinois Supreme Court denied leave to appeal; state action dismissed without prejudice.
- Plaintiffs then filed federal suit, asserting a binding Illinois Appellate Court decision deprived them of due process.
- District court dismissed Count I under Rooker-Feldman and Counts II–III as barred by res judicata; plaintiffs appeal only Count I.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Count I is barred by Rooker-Feldman. | Plaintiffs argue Skinner creates an independent constitutional challenge. | Chicago contends Count I seeks review of a state-court decision and is barred. | Count I barred by Rooker-Feldman. |
| Whether Count I can proceed as an independent constitutional challenge without violating Rooker-Feldman. | Plaintiffs claim to raise a new rule of law about Home Rule construction. | Appellate determination was a judicial, not legislative, rule; not independently reviewable. | No, it is not an independent, non-judicial rule; still barred. |
| Whether the claim is barred by res judicata or case-or-controversy limits. | Plaintiffs argue equitable exceptions apply and the ruling creates ongoing deprivation. | State-court ruling resolved the asserted injury and there is identity of causes of action. | Count I barred by res judicata and lack of justiciable controversy. |
Key Cases Cited
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) (limits federal review of state-court judgments to Supreme Court)
- District of Columbia v. Feldman, 460 U.S. 462 (U.S. 1983) (doctrine precludes lower courts from reviewing state-court decisions)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (narrow scope of Rooker-Feldman; injury from state judgment barred)
- Skinner v. Switzer, 131 S. Ct. 1289 (S. Ct. 2011) (independent federal claim may exist alongside state-court claims; not a rule itself)
- Holt v. Lake County Bd. of Comm’rs, 408 F.3d 335 (7th Cir. 2005) (injury must come from state decision; R-F bar applies)
- Archie v. City of Racine, 847 F.2d 1211 (7th Cir. 1988) (violation of state law not, per se, constitutional violation)
- Remer v. Burlington Area Sch. Dist., 205 F.3d 990 (7th Cir. 2000) (Rooker-Feldman applicability in state-court judgments)