Robert Keith v. Wisconsin Department of Workf
21-2398
| 7th Cir. | Mar 10, 2022Background
- Since 1992 Milwaukee County courts entered custody and child-support orders requiring Robert Keith to pay support; Keith alleges those orders resulted from fraud and deprived him of custodial rights.
- Keith refused to pay and various Wisconsin agencies and officials (DMV, Department of Workforce Development, Department of Revenue, county prosecutors) enforced the support through liens, wage garnishment, interception of unemployment benefits, and criminal charges that produced felony convictions.
- Keith sued in federal court under 42 U.S.C. § 1983 seeking reversal of the state child-support and custody judgments, termination of enforcement actions, return of money collected, expungement of convictions, and $10 million in damages.
- Defendants moved to dismiss on multiple grounds, including Rooker–Feldman, the domestic-relations exception, Eleventh Amendment immunity, Heck, statute of limitations, abstention, preclusion, non‑suable entities, and prosecutorial immunity.
- The district court dismissed for lack of subject‑matter jurisdiction, concluding Rooker–Feldman and the domestic‑relations exception barred Keith’s claims and denied leave to amend.
- The Seventh Circuit affirmed: Rooker–Feldman bars claims seeking to overturn state judgments; the domestic‑relations exception bars federal adjudication of custody/child-support disputes; Heck prevents damages for convictions unless and until convictions are invalidated; jurisdictional dismissal is necessarily without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal court may hear claims that would overturn state child‑support and related enforcement orders (Rooker–Feldman) | Keith: state judgments stemmed from long‑ago fraud; federal court may grant relief. | Defendants: Keith is a state‑court loser seeking federal review of state judgments; Rooker–Feldman bars review. | Rooker–Feldman bars claims that would invalidate or are inextricably bound to state judgments. |
| Whether federal courts may adjudicate custody and child‑support disputes (domestic‑relations exception) | Keith: federal court can review harms caused by state actors. | Defendants: domestic‑relations exception precludes federal courts from resolving core custody/support matters. | Domestic‑relations exception bars Keith’s challenge to custody/child‑support orders. |
| Whether Keith may recover damages for convictions without first having convictions invalidated (Heck) | Keith: seeks damages and expungement for felony convictions arising from enforcement conduct. | Defendants: Heck bars §1983 damages that would imply the invalidity of convictions. | Damages for wrongful conviction are barred until convictions are overturned; dismissal on jurisdictional grounds is without prejudice. |
| Effect of dismissal and leave to amend | Keith: appealed dismissal without showing federal jurisdiction; sought broad relief. | Defendants: dismissal for lack of subject‑matter jurisdiction is appropriate; no leave warranted for claims barred by jurisdictional doctrines. | Court affirmed dismissal for lack of jurisdiction; such dismissal is necessarily without prejudice as to claims that could later be brought if state judgments are invalidated. |
Key Cases Cited
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) (federal courts lack appellate jurisdiction to review state‑court judgments)
- District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983) (Rooker–Feldman principles applied to state‑court loser suits in federal court)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (clarified scope of Rooker–Feldman: federal suits complaining of injuries caused by state‑court judgments are barred)
- Heck v. Humphrey, 512 U.S. 477 (1994) (§1983 damages barred where success would imply invalidity of conviction unless conviction invalidated)
- Ankenbrandt v. Richards, 504 U.S. 689 (1992) (recognizing the domestic‑relations exception to federal jurisdiction over divorce, alimony, and child‑custody decrees)
- Marshall v. Marshall, 547 U.S. 293 (2006) (discussing limits on federal jurisdiction over domestic‑relations matters)
- Kowalski v. Boliker, 893 F.3d 987 (7th Cir. 2018) (applying domestic‑relations principles in federal‑question context and noting jurisdictional dismissal implications)