David Johnson acquired a “certificate of purchase” on a parcel of land in Cook County, Illinois (the “County”) for which taxes had not been paid. Ordinarily the holder of a certificate of purchase can acquire a tax deed from the County if the owner of the property does not pay the delinquent taxes, but, in this instance, it turned out that the County had been mistaken about the delinquency. With Mr. Johnson’s explicit consent, a state circuit court judge entered an order directing that the tax sale be rescinded, Mr. Johnson’s money be returned and the certificate of purchase be cancelled. Mr. Johnson nevertheless petitioned the state court to compel the County to issue him a tax deed, and when that request was denied, he filed this action claiming that the county clerk and other county officials had violated his civil rights under 42 U.S.C. § 1983, the Interstate Land Sales Full Disclosure Act, 15 U.S.C. § 1703, and Illinois state law. The district court concluded that it lacked subject matter jurisdiction under both the Rooker-Feld-man doctrine and the Tax Injunction Act. Because we agree that the district court lacked subject matter jurisdiction over Mr. Johnson’s claims under the Rooker-Feldman doctrine, we affirm its judgment.
I
BACKGROUND
In 2004, Cook County concluded that the property taxes for a particular parcel of real estate had not been paid. Under Illinois law, when an owner fails to pay taxes on real estate, the county collector and the county clerk bring an
in rem
action in state court and request permission to sell the accrued taxes, special assessments, interest and penalties.
See
35 ILCS 200/21-150;
Wilder v. Finnegan,
Mr. Johnson complied with the notice provisions. Before he petitioned the circuit court for a tax deed, however, the County sought a judicial declaration that the tax sale was “in error” because the parcel was owned by a government entity and therefore was exempt from property taxes. See 35 ILCS 200/21-310(a). On September 6, 2006, Mr. Johnson and the County entered into an “agreed order” declaring that the tax sale was in error and directing that the certificate of sale be surrendered within ten days, that the certificate be cancelled and that the county treasurer refund the purchase price plus costs and interest. The Illinois circuit court entered the order. Mr. Johnson does not allege that the County failed to return the money and cancel the certificate of purchase.
Despite the entry of the agreed order, Mr. Johnson petitioned the Illinois circuit court to order the county clerk to issue him the tax deed for the property. Apparently his first application did not follow the proper form, and the circuit court granted him leave to file an amended application, which he did in November 2006. The record contains no further information regarding the outcome of Mr. Johnson’s application, although the complaint in this case states that no deed was issued to Mr. Johnson.
One year later, in October 2007, Mr. Johnson filed this action. He claims that, by refusing to issue him a tax deed, the County violated his constitutional rights to due process, equal protection and freedom from illegal searches and seizures; that the County defrauded him in violation of the Interstate Land Sales Full Disclosure Act; and that the County’s actions ran afoul of state statutes and Illinois common law. In his complaint, Mr. Johnson does not even acknowledge the existence of the agreed order. The defendants moved to dismiss the complaint for lack of subject matter jurisdiction. In granting the motion, the district court concluded that Mr. Johnson was asking, in effect, that the district court review and overturn the agreed order entered in state court, a remedy that the Rooker-Feldman doctrine prohibits. The district court also concluded that the Tax Injunction Act barred the exercise of federal jurisdiction because giving Mr. Johnson the relief he requests would interfere with Illinois’ tax collection practices.
II
DISCUSSION
We review de novo a district court’s determination that it lacks subject matter jurisdiction over a dispute.
Vill. of DePue, Ill. v. Exxon Mobil Corp.,
A.
The district court reasoned that, under the
Rooker-Feldman
doctrine, it lacked subject matter jurisdiction over Mr. Johnson’s claims. The
Rooker-Feldman
doctrine states that federal courts, other than the Supreme Court, do not have jurisdiction to review decisions of state courts in civil cases.
See Exxon Mobil Corp. v. Saudi Basic Indus. Corp.,
Mr. Johnson alleges that he has been injured by the court’s failure to issue him a tax deed. This alleged injury stems directly from the Illinois circuit court’s entry of the agreed order; it is that very order that deprived Mr. Johnson of the right to receive the tax deed and relieved the defendants of any obligation to deed the property to him. In essence, Mr. Johnson is complaining because the defendants are following the circuit court’s order.
See Ritter v. Ross,
It is of no consequence that Mr. Johnson’s complaint does not challenge specifically the agreed order. Nor is it relevant that he has characterized his grievance as a civil rights claim. To determine whether
Rooker-Feldman
bars a claim, we look beyond the four corners of the complaint to discern the
actual injury
claimed by the plaintiff.
Remer v. Burlington Area Sch. Dist.,
Mr. Johnson claims that the
Rooker-Feldman
doctrine does not apply because he has not “lost any ‘decision’ ” and has not been “injured by a state court judgment.” Appellant’s Br. 33. We cannot accept these arguments. Mr. Johnson ignores that he consented to the agreed order’s terms, characterizes it as an order that “[djefendants have drafted” and describes it as “void.”
Id.
In his brief, however, Mr. Johnson does not dispute that the order was a final decision of the state circuit court. At oral argument his attorney submitted that the agreed order was not final. We disagree. A settlement approved by a state court is a judgment for purposes of
Rooker-Feldman. Crestview Vill. Apartments v. U.S. Dep’t of Hous. &
*569
Urban Dev.,
Mr. Johnson’s complaint and his appellate brief make crystal clear that he is claiming that he has been injured by the agreed order. The thrust of his argument is that the state court’s judgment was in error. He alleges in his complaint that the property is not tax exempt, that defendants “purposely or recklessly ignored publicly available information that the land is not exempt from taxation in the state of Illinois,” and that the land is “not exempt from taxation under Article IX, Section 6 of the Constitution of Illinois.” R.l at 2, 7. In his opening appellate brief, he submits that he “has purchased delinquent land not exempt from taxation,” that “the delinquent land was not sold through inadvertence] or mistake,” and that the agreed order “falsely stated that the delinquent land was exempt from taxation.” Appellant’s Br. 6, 18, 28. The way to remedy these alleged wrongs is not through an action in the district court. If Mr. Johnson believes the state court was wrong about the tax-exempt status of the property or that he was induced fraudulently to sign away his rights to receive the tax deed, his remedy is to ask the state circuit court to set aside the agreed order. An Illinois court can set aside a consent order on the basis of newly discovered evidence or on a showing that the agreement was the result of a fraudulent misrepresentation.
See In re Marriage of Nienhouse,
Mr. Johnson also protests that the agreed order is irrelevant because the certificate of purchase was a final judgment guaranteeing him the right to receive a tax deed and therefore could not be voided by the agreed order. We cannot accept this argument. It is well established under Illinois law that a tax purchaser is not automatically entitled to receive a tax deed. For instance, if the tax purchaser does not comply with the requirement that he give notice of the deficiency to the owner of the property, he will not be granted a tax deed.
See
35 ILCS 200/22-5, 200/22-40(a). Similarly, an order declaring that the tax sale was in error voids the certificate of purchase and revokes the tax purchaser’s right to receive a tax deed.
See
35 ILCS 200/21-310;
see also RTC Commercial Assets Trust 1995-NP3-1 v. Phoenix Bond & Indem. Co.,
Mr. Johnson also contends that the
Rooker-Feldman
doctrine does not apply because his complaint alleges that the defendants acted under the color of state law. In support of this argument, Mr.
*570
Johnson relies heavily on
Nesses v. Shepard,
B.
In addition to his civil rights claims, Mr. Johnson’s complaint also alleges a violation of the Interstate Land Sales Full Disclosure Act, 15 U.S.C. §§ 1701-1720. We do not have subject matter jurisdiction to entertain this claim. A district court has federal question jurisdiction only if the complaint shows, on its face, that a federal claim is “sufficiently substantial.”
See Greater Chicago Combine & Ctr., Inc. v. City of Chicago,
Mr. Johnson’s claim under the Interstate Land Sales Full Disclosure Act is insubstantial and frivolous. The Act prohibits property owners from engaging in fraud in the sale or lease of certain types of real estate. As relevant here, the prohibitions in the Act apply only to a “sale or lease, or offer to sell or lease any lot” that is not subject to an exemption.
See
15 U.S.C. § 1703(a)(2). The defendants did not sell any property to Mr. Johnson. The County does not acquire ownership of property, and thus cannot sell it, simply because taxes go unpaid. Mr. Johnson was assigned a “certificate of purchase” by Z Financial, which had paid the delinquent taxes on the property. Thus, the County essentially sold the right to collect the back taxes from the property owner, who was entitled to reimburse Mr. Johnson for the delinquent taxes and retain ownership.
See
35 ILCS 200/21-345. If the property owner failed to pay, Mr. Johnson then had to petition the circuit court and provide proof that he had given the taxpayer the required notice before he could receive a deed.
See
35 ILCS 200/22-30, 200/22-40; Cook County Circuit Ct. R. 10.3. The County did not sell the property to Mr. Johnson, and Mr. Johnson never owned it.
See Beth-El All Nations Church,
Even if a tax sale were a “sale” of property for purposes of the Act, Mr. Johnson’s claim would be meritless for another reason. The Act specifically exempts from its reach “the sale or lease of real estate by any government or government agency.” 15 U.S.C. § 1702(a)(5). *571 Cook County, through the county collector and the county clerk, administered the tax sale and issued the certificate of purchase. The County, a government entity, is exempt from liability for land sales under the Act.
C.
The district court correctly concluded that it lacked subject matter jurisdiction to decide Mr. Johnson’s claims. We briefly address, however, the district court’s ruling that the Tax Injunction Act (“TIA”) provides an additional basis for finding a lack of jurisdiction. The TIA deprives district courts of jurisdiction when a party seeks to “enjoin, suspend or restrain the assessment, levy or collection of any tax under State law where a plain, speedy and efficient remedy may be had in the courts of such State.” 28 U.S.C. § 1341. Essentially, it blocks taxpayers from suing in federal court to tie up a state’s “rightful tax revenue” or to avoid paying state taxes, both of which would reduce the flow of tax revenue.
Levy v. Pappas,
Mr. Johnson does not seek to tie up the County’s tax revenue or to avoid paying taxes. The taxes originally, but erroneously, assessed on the property were paid at the tax sale. The ultimate relief Mr. Johnson seeks — a tax deed— would not deprive the County of tax revenue. Cf
. Levy,
Because Mr. Johnson has not asked the court for relief that would impede the collection of taxes or reduce the flow of tax revenue to Illinois, the TIA does not bar his claims.
See Hibbs,
Affirmed