Jakupovic v. Curran
2017 U.S. App. LEXIS 4302
| 7th Cir. | 2017Background
- Jakupovic, a Cook County resident, was charged in Lake County (telephone harassment). The Lake County trial court ordered pretrial detention and then release conditioned on electronic monitoring and a Lake County residence after an ODARA review.
- Lake County Sheriff’s Department required monitored detainees to have a Lake County residence; lacking one, Jakupovic was not released and was detained for six days.
- Jakupovic filed emergency motions in state court challenging the residence-based monitoring condition; the trial court denied relief, scheduled a bond-modification hearing, and Jakupovic pled guilty before that hearing; he did not pursue state appeals.
- Jakupovic sued county officials in federal court under 42 U.S.C. § 1983 (Eighth and Fourteenth Amendment claims) and Illinois false imprisonment, alleging unlawful detention caused by defendants’ refusal to implement electronic surveillance.
- The district court dismissed the complaint with prejudice under Rule 12(b)(6). The Seventh Circuit vacated and remanded, holding the federal court lacked subject-matter jurisdiction under the Rooker–Feldman doctrine and ordering dismissal without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal court has jurisdiction or Rooker–Feldman bars suit | Jakupovic says he challenges defendants’ execution of a policy that caused unnecessary six-day detention, not the state-court judgment | Defendants argue the federal suit effectively attacks state-court orders and is therefore jurisdictionally barred | Rooker–Feldman bars jurisdiction because adjudicating the federal claims would require overturning or rejecting the state-court rulings |
| Whether the federal claims are “inextricably intertwined” with state judgments | Jakupovic contends the claims target unlawful policies/practices, independent of the state court’s ruling | Defendants say the alleged misconduct implemented the state court’s bond condition and so is inseparable from that judgment | Court: Claims are inextricably intertwined because proving defendants’ liability would require finding the state court erred |
| Whether Jakupovic had a reasonable opportunity to raise issues in state court | Jakupovic implies practical obstacles justified federal filing | Defendants point to multiple state-court proceedings where he could (and did) raise the issue | Court: He had at least three chances (emergency motion, reconsideration, motion to modify bond) — so he had a reasonable opportunity |
| Proper disposition when Rooker–Feldman applies | Jakupovic sought merits adjudication and dismissal with prejudice | Defendants sought dismissal; district court dismissed with prejudice | Court: Dismissal for lack of jurisdiction must be without prejudice; vacated district court judgment and remanded with instruction to dismiss without prejudice |
Key Cases Cited
- Rooker v. Fid. Tr. Co., 263 U.S. 413 (establishes that lower federal courts lack appellate authority over state-court judgments)
- District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (clarifies limits on federal review of state-court adjudications)
- Sykes v. Cook Cty. Cir. Ct. Prob. Div., 837 F.3d 736 (7th Cir.) (applies Rooker–Feldman to bar federal review where federal claims are tied to state-court orders)
- Kelley v. Med-1 Sols., LLC, 548 F.3d 600 (7th Cir.) (explains when pre-judgment conduct is nonetheless inextricably intertwined with a state judgment)
- Taylor v. Fed. Nat’l Mortg. Ass’n, 374 F.3d 529 (7th Cir.) (framework for distinguishing independent federal claims from state-judgment challenges)
- Lance v. Dennis, 546 U.S. 459 (discusses the narrow scope of Rooker–Feldman)
- Frederiksen v. City of Lockport, 384 F.3d 437 (7th Cir.) (directs dismissal without prejudice when Rooker–Feldman requires dismissal for lack of jurisdiction)