Whittington v. Saline County Illinois Circuit Judge, 3:17-cv-00185

Background

Plaintiff Brian Whittington, proceeding pro se and in forma pauperis, sued Saline County officials seeking relief from long‑standing child‑support wage withholding and related state‑court orders.
He alleged lack of personal jurisdiction because he was incarcerated in Mississippi when the state proceedings began and that a sworn statement listing his Illinois address was false and unverified.
Claims in the amended complaints: (1) procedural and substantive due process violations; (2) constitutional challenge to 305 ILCS 5/10‑1 as gender‑discriminatory; (3) fraud by state court officials for endorsing the false address; and (4) intentional/negligent infliction of emotional distress.
He sought declaratory relief and compensatory and punitive damages for lost wages (tens of thousands of dollars), emotional injury, and collateral consequences.
The district court screened the amended pleadings under 28 U.S.C. § 1915(e)(2) and concluded jurisdictional and pleading defects prevented relief; the court dismissed the complaint with prejudice as futile and denied IFP status.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal court may hear Whittington's claims attacking a state‑court child‑support judgment	Whittington contends state court lacked jurisdiction and seeks federal relief for due process, fraud, and emotional distress	Defendants argue the Rooker‑Feldman doctrine bars federal review of state‑court judgments	Dismissed for lack of jurisdiction under Rooker‑Feldman; federal court cannot redress injuries that stem from an adverse state judgment
Whether Whittington can obtain injunctive/monetary relief for alleged state‑court procedure defects	He argues procedural errors and a false sworn statement deprived him of due process and caused damages	Defendants: relief must be sought in state appellate courts; federal district court lacks authority absent extraordinary circumstances	Claim barred by Rooker‑Feldman; state appellate process (and ultimately the U.S. Supreme Court) is the proper route
Whether 305 ILCS 5/10‑1 is unconstitutional under Equal Protection as applied	Whittington asserts the statute operates to disadvantage men; cites statistics showing women receive custody/support more often	Defendants: claim is either barred by Rooker‑Feldman or inadequately pled; statute is gender neutral and disparate impact alone is insufficient	Dismissed: either jurisdictionally barred or facially insufficient—plaintiff failed to allege purposeful gender‑based discrimination beyond statistics
Whether plaintiff stated viable fraud or emotional‑distress claims against state actors	He alleges officials knowingly endorsed a false address causing financial and emotional harm	Defendants: these injuries flow from the state judgment and cannot be relitigated in federal court	Dismissed under Rooker‑Feldman; claims arise from the state judgment and are precluded in federal district court

Key Cases Cited

Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) (establishes that federal district courts lack appellate jurisdiction over state court judgments)
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983) (clarifies limits on federal district court review of state judicial proceedings)
Lance v. Dennis, 546 U.S. 459 (2006) (explains Rooker‑Feldman scope for "state‑court losers")
Garry v. Geils, 82 F.3d 1362 (7th Cir. 1996) (applies Rooker‑Feldman to bar federal review of state judicial decisions)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state plausible claim beyond speculation)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions not entitled to the assumption of truth)
Craig v. Boren, 429 U.S. 190 (1976) (gender classifications require important governmental objectives and substantial relation)
Personnel Administrator of Massachusetts v. Feeney, 442 U.S. 256 (1979) (disparate impact alone generally insufficient to prove discriminatory purpose)
Washington v. Davis, 426 U.S. 229 (1976) (disparate impact is insufficient without discriminatory purpose)
Alston v. City of Madison, 853 F.3d 901 (7th Cir. 2017) (disparate impact requires identification of policy causing the impact)