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524 F. App'x 290
7th Cir.
2013
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Background

  • Hadley, a former Illinois inmate, sues under 42 U.S.C. § 1983 claiming unlawful reimprisonment after parole and related wrongful-conviction claims.
  • He challenged his 1976 murder conviction and alleged the plea agreement was breached by reliance on presentence aggravating evidence.
  • Parole began in 2007; he allegedly violated parole by leaving Illinois, leading to arrest and revocation in 2009 and reincarceration until 2010.
  • Plaintiff asserted state-created harms and sought damages from multiple state and local defendants, including jails, counties, governor, and the Office of the State Appellate Defender.
  • Lower court dismissed several defendants under Eleventh Amendment, and allowed certain individual-capacity claims to proceed; district court held qualified immunity for some officers and explained Heck and Rooker-Feldman issues.
  • On appeal, Hadley contends jurisdictional bars do not apply and seeks relief for the underlying conviction and parole-revocation harms, while defendants argue these bars foreclose the claims.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Rooker-Feldman bars Hadley’s challenge to the state murder conviction Hadley argues no jurisdictional bar. Rooker-Feldman bars review of state-court judgments. Rooker-Feldman barred review of the conviction.
Whether Heck bars damages for claims tied to a criminal conviction or parole revocation Hadley seeks damages without valid state-court relief. Heck applies when relief would undermine a conviction or parole status. Heck bars damages for these claims.
Whether the district court properly granted qualified immunity to Davinroy, Chaney, and Engelman Plaintiff alleges clearly established rights were violated. Defendants acted reasonably given unclear standards. Qualified immunity affirmed; no clearly established right shown.
Whether the governor’s personal involvement can support liability Governor failed to correct unlawful detention. Governor not personally involved in revocation. No personal involvement found; claims fail.

Key Cases Cited

  • Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (limits jurisdiction to review state judgments; supports Rooker-Feldman bar)
  • Dist. of Columbia Ct. of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (Rooker-Feldman framework clarified)
  • Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) (originally articulates jurisdictional constraint on federal review of state judgments)
  • Pennzoil Co. v. Texaco, Inc., 481 U.S. 1 (U.S. 1987) (federal review premised on a state-court judgment is barred)
  • Preiser v. Rodriguez, 411 U.S. 475 (U.S. 1973) (establishes availability of habeas relief for prison conditions or custody issues)
  • Walker v. O’Brien, 216 F.3d 626 (7th Cir. 2000) (Habeas relief relevant to §1983 when custody status is implicated)
  • Simpson v. Nickel, 450 F.3d 303 (7th Cir. 2006) (clarifies Heck applicability post-custody)
  • Burd v. Sessler, 702 F.3d 429 (7th Cir. 2012) (Heck bar when habeas relief could have been pursued)
  • Hadley v. Holmes, 341 F.3d 661 (7th Cir. 2003) (prev. §2254 petitions during incarceration; relevance to relief)
  • In re Hadley, 550 U.S. 902 (U.S. 2007) (Supreme Court docket where clerk not to accept noncriminal filings without fee)
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Case Details

Case Name: Hadley v. Quinn
Court Name: Court of Appeals for the Seventh Circuit
Date Published: Apr 25, 2013
Citations: 524 F. App'x 290; No. 12-3282
Docket Number: No. 12-3282
Court Abbreviation: 7th Cir.
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    Hadley v. Quinn, 524 F. App'x 290