Lawrence Lennon v. City of Carmel, Indiana
2017 U.S. App. LEXIS 13448
| 7th Cir. | 2017Background
- Motorists cited under Carmel, Indiana Ordinance § 8-2 (which incorporated Indiana traffic law) paid fines, defaulted, were convicted, or entered deferral agreements; none appealed in Indiana courts.
- Indiana Court of Appeals later held the ordinance invalid under Indiana home-rule law in Maraman v. City of Carmel.
- Plaintiffs sued in federal district court under 42 U.S.C. § 1983 and state unjust-enrichment claims against numerous local and state actors, seeking damages, expungement, and a stay of BMV actions.
- District court dismissed for multiple reasons: lack of standing for some plaintiffs, Rooker–Feldman jurisdictional bar for most claims, abandonment of other claims, and failure to state a claim for the remainder.
- Seventh Circuit affirmed dismissal, holding most claims review state-court judgments (Rooker–Feldman), limited a few surviving claims (pre-judgment stops and deferral plaintiffs), and found those survivors substantively deficient or barred by immunity and by lack of a § 1983 violation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal court may review state traffic judgments | Plaintiffs: state-judgments are invalid (ordinance void), so federal relief can follow | Defendants: Rooker–Feldman bars federal review of state-court judgments | Court: Rooker–Feldman bars review for plaintiffs who lost in state court; most claims dismissed without prejudice |
| Whether any claims are independent of state judgments (pre-judgment stops) | Plaintiffs: injuries from traffic stops and misleading citations are independent | Defendants: claims are speculative, lacking standing and jurisdiction | Court: Pre-judgment claims weak and likely barred; district court’s dismissal affirmed |
| Claims by deferral-agreement plaintiffs (no final conviction) | Plaintiffs: deferral agreements were misleading/overly costly and violated rights | Defendants: allegations fail to state constitutional violation; plaintiffs got quid pro quo (no prosecution) | Court: Rooker–Feldman not applicable but plaintiffs fail to plead a § 1983 constitutional claim; dismissed with prejudice |
| Personal liability, municipal liability, and immunity | Plaintiffs: various officials and entities responsible for systemic wrongdoing | Defendants: no personal involvement alleged; municipal court/judge immune; BMV is state actor not suable under § 1983; no Monell showing | Court: dismissal for lack of personal involvement, absolute judicial immunity, Monell failure, and Eleventh‑type immunity for BMV affirmed |
Key Cases Cited
- Rooker v. Fid. Tr. Co., 263 U.S. 413 (1923) (federal district courts lack authority to review state-court judgments)
- Dist. of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983) (Rooker–Feldman framework applied to state-court adjudications)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (clarifies scope of Rooker–Feldman)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (personal involvement and pleading standards in constitutional claims)
- Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658 (1978) (municipal liability requires an official policy or custom)
- Stump v. Sparkman, 435 U.S. 349 (1978) (absolute judicial immunity for judicial acts)
- Will v. Michigan Dep’t of State Police, 491 U.S. 58 (1989) (states and state agencies are not "persons" under § 1983)
- Skinner v. Switzer, 562 U.S. 521 (2011) (Supreme Court review is the proper federal avenue to review state-court judgments)