Gilbank v. Wood County Department of Human Services

Federal 7th Circuit Court
Civil Court
Rooker-Feldman Doctrine
Citation
Case Number: 
No. 22-1037
Decision Date: 
August 1, 2024
Federal District: 
W.D. Wis.
Holding: 
Affirmed.
Judge: 
HAMILTON

Plaintiff, after losing custody of her daughter in a state court child-protection case and then regaining custody a year later, filed a federal lawsuit alleging that various officials involved in the state court proceedings violated her federal constitutional rights. The district court granted summary judgment for all defendants, finding that some of the claims were barred by the Rooker-Feldman doctrine and that all other claims failed on the merits. A majority of the Seventh Circuit sitting en banc affirmed the judgment of the district court dismissing the complaint as well as the order granting summary judgment based on the merits of plaintiff’s claims. A majority of the justices also rejected plaintiff’s argument that she lacked a reasonable opportunity to litigate her claims in state court and eliminated the “fraud exception” of the Rooker-Feldman doctrine; however, a different majority of the court held that jurisdiction over the plaintiff’s claims was not barred by the Rooker-Feldman doctrine because they did not seek a federal district court’s review and rejection of the state court’s judgments. Additionally, all of the Seventh Circuit judges agreed that the court should no longer rely on the “inextricably intertwined” language in applying the Rooker-Feldman doctrine. (BRENNAN, JACKSON-AKIWUMI, and PRYOR, concurring and KIRSCH, concurring in part and dissenting in part, joined by SYKES, SCUDDER, ST. EVE and LEE and joined as to Part I by EASTERBROOK.)