Jakupovic v. Curran

Federal 7th Circuit Court
Civil Court
Rooker-Feldman Doctrine
Citation
Case Number: 
No. 16-3374
Decision Date: 
March 10, 2017
Federal District: 
N.D. Ill., E. Div.
Holding: 
Vacated and remanded

Dist. Ct. lacked jurisdiction under Rooker-Feldman doctrine to consider plaintiff’s section 1983 action alleging that his six-day detainment arising out of defendants’ requirement that plaintiff have Lake County residence before he could be released on bail while being subject to electronic monitoring violated his 8th and 14th Amendment rights. Record showed that plaintiff had unsuccessfully litigated said bail bond requirement in state court on three separate occasions prior to filing instant lawsuit, and Rooker Feldman doctrine served to deprive Dist. Ct. of jurisdiction to consider instant lawsuit, where plaintiff essentially sought to set aside adverse state court judgments regarding his claim. Moreover, Ct. found that plaintiff’s claim of false imprisonment was inextricably intertwined with prior state court judgment, since there was no conceivable way to address plaintiff’s claim without overturning prior state court orders that kept plaintiff detained for lack of Lake County residence.