General Parker v. Kevin Lyons
2014 U.S. App. LEXIS 12757
| 7th Cir. | 2014Background
- Parker sought a seat on the Peoria School District 150 board and filed a nominating petition; Illinois 10 ILCS §5/29-15 bars infamous-crime felons from public office, and Parker had a felony theft conviction from the 1980s without a pardon.
- Lyons, the Peoria County state’s attorney, filed a quo warranto action in Illinois court to block Parker’s candidacy and remove him from the ballot.
- The Illinois court held Parker barred from the office, enjoined him from running, and removed his name from the ballot after a rushed hearing with limited notice.
- Parker filed a federal suit alleging due process and equal-protection violations in the enforcement of the statute, and a facial challenge to the statute itself.
- The district court dismissed based on Rooker-Feldman, immunity, and claim preclusion; Parker appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rooker-Feldman applicability | Parker asserts Rooker-Feldman bars the federal claims. | Defendants argue Rooker-Feldman bars the claims as a collateral attack on state proceedings. | Rooker-Feldman does not apply. |
| Immunity and official-capacity claims | Parker seeks damages/injunctions for Lyons’s actions in enforcement. | Lyons enjoys prosecutorial immunity; Eleventh Amendment bars official-capacity damages; state actors/defendants may differ. | Immunity and Eleventh Amendment bar damages; injunctive relief against Lyons unavailable. |
| Facial challenge and claim preclusion | Illinois statute unconstitutional on its face; equitable exception to claim preclusion may apply due to rushed proceedings. | Claim preclusion applies; Parker failed to raise constitutional claims in state court; no equitable exception needed. | Facial challenge rejected on merits; claim preclusion applicable, and Parker’s arguments fail on merits. |
| Ex parte Young and state-suit viability | Young allows ongoing federal relief against the state. | Only state official (Lyons) is proper defendant; Young relief not available here. | No Ex parte Young remedy; no federal claim against the state. |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (Rooker-Feldman scope clarified; final-state-judgment concept)
- Mothershed v. Justices of the Supreme Court, 410 F.3d 602 (9th Cir. 2005) (Rooker-Feldman limitation on pending-state-review scenarios clarified)
- Nesses v. Shepard, 68 F.3d 1003 (7th Cir. 1995) (Support for independent federal claims despite state proceedings)
- McDonough Assocs., Inc. v. Grunloh, 722 F.3d 1043 (7th Cir. 2013) (Ex parte Young; official-capacity actions and ongoing federal requirements)
- Verizon Md., Inc. v. Pub. Serv. Comm’n of Md., 535 U.S. 635 (U.S. 2002) (Necessity of federal-law claim to support Young relief)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (Pleadings must allege plausible governmental purpose, not mere conclusory assertions)
- Talley v. Lane, 13 F.3d 1031 (7th Cir. 1994) (Equal-protection scrutiny for felon-disqualification)
- Clements v. Fashing, 457 U.S. 957 (U.S. 1982) (Rational basis review for state-ballot restrictions)
- Richardson v. Ramirez, 418 U.S. 24 (U.S. 1974) (Voting rights and fundamental-right analysis guidance)