Martin v. Greenwood
1:24-cv-01421
N.D. Ill.Dec 19, 2024Background
- Thomas Edward Martin, former owner of Antares Iron & Copper, Inc., sued John Robert Greenwood (prosecutor), Mary Jo Stvan (plan administrator), and Definiti, LLC.
- Martin was convicted in 2019 of theft and wire fraud for withdrawing funds from the company’s 401(k) plan to cover business expenses; his conviction was affirmed on appeal.
- He alleges Stvan mishandled legal fees and plan administration, and Greenwood committed prosecutorial misconduct.
- Plaintiff seeks to establish ownership of the disputed plan funds, vacate his conviction via civil rights claims, and remedy alleged fiduciary breaches.
- Defendants moved to dismiss under Rules 12(b)(1) (lack of jurisdiction) and 12(b)(6) (failure to state a claim).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal jurisdiction over ERISA claim | Martin claims ERISA interpleader relief is proper to determine fund ownership | Rooker-Feldman bars federal review of state court judgment | Dismissed with prejudice; Rooker-Feldman bars claim |
| § 1983 civil rights claim (Greenwood) | Greenwood’s misconduct at trial violated Martin’s federal rights | Claims barred by Rooker-Feldman, statute of limitations, and Heck | Dismissed with prejudice; all bars apply |
| Due Process claim (Greenwood) | Greenwood’s trial conduct violated Due Process | Prosecutorial immunity, untimeliness, and Rooker-Feldman bar claim | Dismissed with prejudice on multiple grounds |
| § 1983/state law claims (Stvan) | Stvan’s errors and fiduciary misconduct violated civil rights, state law | Not a state actor, claims are too late, and witnesses have absolute immunity | Dismissed; no claim as to § 1983, state claim dismissed without prejudice |
Key Cases Cited
- Rooker v. Fid. Tr. Co., 263 U.S. 413 (Rooker-Feldman doctrine prohibiting federal review of state court judgments)
- District of Columbia Ct. of Appeals v. Feldman, 460 U.S. 462 (Extension of Rooker-Feldman doctrine)
- Heck v. Humphrey, 512 U.S. 477 (§ 1983 claim not available when conviction stands)
- Briscoe v. LaHue, 460 U.S. 325 (Witness immunity from § 1983 liability)
- Van de Kamp v. Goldstein, 555 U.S. 335 (Prosecutorial absolute immunity for acts within prosecutorial function)