McDonald v. Adamson
840 F.3d 343
7th Cir.2016Background
- Donald McDonald, an Illinois inmate at Stateville, sued in the Illinois Court of Claims in 2010 alleging violations of his First Amendment free-exercise rights (e.g., lack of weekly Friday Muslim services, stolen prayer rugs and Arabic cassette tapes) and sought damages and an injunction.
- While the Court of Claims delayed issuing a decision for over two years, McDonald filed a pro se § 1983 suit in federal district court in March 2013 against Stateville officials (official-capacity defendants), seeking only injunctive relief.
- The Illinois Court of Claims issued an adverse two-page decision in July 2013 rejecting McDonald’s allegations (addressing only the Friday service claim).
- Defendants then moved to dismiss the federal complaint as barred by res judicata based on the Court of Claims judgment; the district court granted dismissal.
- On appeal the defendants conceded res judicata did not apply; the Seventh Circuit reversed, holding the Court of Claims lacked the competence to produce a preclusive final judgment on federal constitutional claims and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Court of Claims judgment precludes McDonald’s § 1983 claim (res judicata) | McDonald proceeded in federal court because his § 1983 claim was separate and proper there | Court of Claims decision bars relitigation of the same claims | Reversed: res judicata inapplicable because Court of Claims is not a "court of competent jurisdiction" for federal constitutional claims under Illinois preclusion law |
| Whether collateral estoppel bars relitigation of specific factual issues decided by the Court of Claims | McDonald did not concede those factual findings; his federal complaint contains conceivably different factual allegations | Defendants argued (for first time on appeal) that the Court of Claims conclusively resolved specific factual issues (weekly services, stolen rugs, tapes) | Not reached: court declined to consider collateral estoppel raised first on appeal; defendants bore burden to raise it below |
| Proper standard of review for dismissal under Rule 12(b)(6) | N/A (procedural) | N/A | De novo review; accept pleaded facts and draw reasonable inferences for plaintiff |
| Whether mootness or voluntary cessation defeats the § 1983 claim | McDonald did not concede mootness despite evidence services were later offered | Defendants argued the weekly-service claim may be moot due to changed practice and plaintiff’s thank-you note | Not decided: left for district court on remand; voluntary cessation doctrine applies and defendants have burden to show unlikelihood of recurrence |
Key Cases Cited
- Palka v. City of Chicago, 662 F.3d 428 (7th Cir. 2011) (res judicata protects finality and bars relitigation of claims that could have been raised)
- Arlin-Golf, LLC v. Vill. of Arlington Heights, 631 F.3d 818 (7th Cir. 2011) (Illinois preclusion law requires a final judgment by a court of competent jurisdiction)
- Grogan v. Garner, 498 U.S. 279 (1991) (collateral estoppel can preclude issues even when the prior tribunal lacked jurisdiction over the later cause of action)
- Friends of the Earth, Inc. v. Laidlaw Envtl. Servs., 528 U.S. 167 (2000) (voluntary cessation and mootness doctrine; defendant bears heavy burden to show challenged conduct will not recur)
- Adair v. Sherman, 230 F.3d 890 (7th Cir. 2000) (party asserting collateral estoppel bears burden of raising it below)
- Marshall-Mosby v. Corporate Receivables, Inc., 205 F.3d 323 (7th Cir. 2000) (court will not affirm judgment based on affirmative defenses raised for the first time on appeal)