Sykes v. Cook County Circuit Court Probate Division, 2016 U.S. App. LEXIS 16778

Background

Gloria Jean Sykes, a litigant in a Cook County probate guardianship matter for her mother Mary, brought her service dog Shaggy to a hearing on a "Motion for Reasonable Accommodations."
Judge Aicha MacCarthy questioned Sykes about Shaggy, struck Sykes’s motion without prejudice, and entered an order prohibiting Sykes from returning with Shaggy without leave of court.
Sykes previously sued in federal court alleging ADA violations related to the guardianship proceedings; that suit was dismissed under Rooker–Feldman and probate/abstention principles and affirmed.
Sykes filed a new federal suit alleging the courtroom ban of Shaggy violated her rights under Title II of the ADA; the district court dismissed for lack of subject-matter jurisdiction (Rooker–Feldman, probate exception, and Younger abstention).
On appeal the Seventh Circuit: (1) rejected the probate-exception and Younger grounds as decisive here, and (2) affirmed dismissal under Rooker–Feldman because relief would require overturning the state court order banning Shaggy.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal court has jurisdiction over Sykes’s ADA claim based on judge’s questioning and banning of service dog	Sykes: claim targets judge's wrongful conduct and a practice of ADA violations, not an attempt to overturn the state order	Defendants: claim is inextricably intertwined with the state-court order banning Shaggy; federal court lacks authority under Rooker–Feldman	Court: Rooker–Feldman applies—granting relief would require setting aside the state-court order, so dismissal for lack of jurisdiction affirmed
Whether probate-exception bars federal jurisdiction	Sykes: the ADA claim is independent of probate issues	Defendants: probate court custody over persons/property and probate expertise counsel dismissal	Court: probate-exception inapplicable here because the ADA claim is unrelated to probate law and only coincidentally arose in a probate courtroom
Whether Younger abstention requires dismissal (state proceedings ongoing at district court stage)	Sykes: federal relief appropriate	Defendants: federal courts should abstain from ongoing state judicial proceedings	Court: Younger abstention was applied by district court when state case was pending, but moot on appeal because decedent died; Younger not dispositive on appeal
Whether Title II requires permitting service animals in courtrooms and scope of permissible questioning	Sykes: service animal protected by Title II; judge impermissibly questioned and excluded Shaggy	Defendants: judge’s actions resulted in a court order excluding the dog	Court: explains substantive ADA standards (service animals allowed; limited permissible questions) but finds Rooker–Feldman bars federal adjudication here

Key Cases Cited

Rooker v. Fidelity Trust Co., 263 U.S. 413 (federal district courts lack authority to reverse state-court judgments)
D.C. Court of Appeals v. Feldman, 460 U.S. 462 (same; Rooker–Feldman doctrine applied to lower federal courts)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (limits and scope of Rooker–Feldman; doctrine occupies narrow ground)
Tennessee v. Lane, 541 U.S. 509 (Title II of ADA can abrogate state sovereign immunity for access to courts)
Younger v. Harris, 401 U.S. 37 (federal courts should abstain from interfering with ongoing state prosecutions and certain state judicial proceedings)
Marshall v. Marshall, 547 U.S. 293 (scope and limits of the probate exception to federal jurisdiction)
Skinner v. Switzer, 562 U.S. 521 (distinguishing Rooker–Feldman from a plaintiff asserting an independent claim)
Lance v. Dennis, 546 U.S. 459 (limits on applying Rooker–Feldman to nonparties/privity concerns)
Kelley v. Med-1 Solutions, 548 F.3d 600 (7th Cir.) (Rooker–Feldman bars claims that would require determining state court erred in its judgment)
Stroman Realty, Inc. v. Martinez, 505 F.3d 658 (7th Cir.) (elements for Younger abstention)