Wereko v. WESTWARD360, 1:23-cv-00651

Vanessa Wereko, a pro se plaintiff, sued a condominium association, board members, its lawyer, a property management company and its employee, multiple Illinois state judges and justices, court employees, and Illinois Department of Human Rights staff.
The dispute centers around Wereko’s ownership of a condominium unit and ensuing conflicts over a tenant’s access to storage, an eviction/collection action in state court, and board/management practices.
Wereko alleges she was denied proper process in the state court proceedings, suffered harm due to the actions/inactions of court staff and judges, and faced loss of rental income and failed attempts to sell her unit.
She asserts federal civil rights, fair housing, and state law claims arising from the outcome and conduct of the state court eviction and assessment collection proceedings.
Several defendants moved to dismiss based on lack of federal jurisdiction under the Rooker-Feldman doctrine, arguing her claims were attacks on state litigation outcomes.
The court reviewed all claims to determine whether any could proceed independently of the state court proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Subject Matter Jurisdiction (Rooker-Feldman)	Federal court can hear claims arising from alleged constitutional, statutory, and civil rights violations during/related to state case.	Rooker-Feldman bars federal jurisdiction over claims seeking review or reversal of state court judgments.	Court lacks jurisdiction under Rooker-Feldman; claims dismissed.
Claims under Fair Housing Act, Title VII, §1981, §1982, §1983	Association, board, and state actors improperly evicted Wereko and denied her rights based on discriminatory and unlawful conduct.	Claims are collateral attacks on state court proceedings and not independent federal claims.	All counts are barred as improper collateral attacks on state judgments.
Default against Unresponsive Defendants	Default should be granted against parties who did not answer complaint.	No default can issue where court lacks subject matter jurisdiction.	Motion for default denied as moot.
Potential Independent Claims (e.g., IDHR investigation)	Some actions (e.g., IDHR procedures/account statements) are independent of state case.	All claims are intertwined with the state proceedings; any review would require reviewing state court actions.	No claim sufficiently independent to escape Rooker-Feldman bar.

Rooker v. Fid. Trust Co., 263 U.S. 413 (federal district courts lack jurisdiction to review state court decisions)
D.C. Court of Appeals v. Feldman, 460 U.S. 462 (same principle as Rooker, federal district courts not courts of appeal from state courts)
Mains v. Citibank, N.A., 852 F.3d 669 (application of Rooker-Feldman doctrine to closely related claims)
Johnson v. Orr, 551 F.3d 564 (framing claims as civil rights violations does not evade Rooker-Feldman)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (summary of Rooker-Feldman’s limited but absolute bar on federal review of state court losers’ claims)