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