Andrade v. City of Hammond, Ind.

Dist. Ct. erred in dismissing plaintiff’s section 1983 and 1985 action, alleging that defendants-City and certain City employees violated plaintiff’s due process rights when making administrative determination regarding his rental property, where Dist. Ct. based its dismissal on Rooker-Feldman doctrine, which prohibits lower federal courts from reviewing state-court judgments. Rooker-Feldman doctrine did not apply, where plaintiff’s claims are not direct challenges to any state-court order, and where: (1) defendants’ challenged conduct, such as defying plaintiff’s subpoena and providing false testimony at hearing, occurred prior to any judicial involvement. Moreover, plaintiff’s federal claims, which could exist without any state-court judgment, were capable of being separated from instant state-court judgment. As such, Dist. Ct. may exercise jurisdiction over plaintiff’s case.