Dist. Ct. did not err in dismissing on Rooker-Feldman grounds plaintiff’s action seeking declaration that neither IEPA nor Illinois Pollution Control Bd. had jurisdiction over plaintiff’s acid dumping activities that involved plaintiff’s industrial wells located in Illinois. Plaintiff previously litigated said issue in Illinois state courts, which rejected instant jurisdictional argument under Illinois state law. As such, instant action would purport to protect plaintiff from any future enforcement action brought by IEPA, and thus would run contrary to Rooker-Feldman doctrine, which precludes lower federal courts from reviewing propriety of final state-court judgment. Moreover, notions of claim preclusion prohibits plaintiff from making second attempt to litigate instant jurisdictional question, where jurisdictional question was present in both actions, and where facts in both actions arose out of same nuclear facts, and parties in both actions were identical. Also, Eleventh Amendment precludes federal court from ordering any relief against state agency based on state law.
Federal 7th Circuit Court
Civil Court
Rooker-Feldman Doctrine