Lennon v. City of Carmel, Ind.

Dist. Ct. did not err in granting defendants-city officials’ motion to dismiss under Rooker-Feldman Doctrine plaintiffs’ section 1983 action alleging that defendants engaged in conspiracy to deprive them of their civil rights by ticketing them for traffic violation under city ordinance that resulted in unappealed fines or entry of deferral agreements. While Indiana court eventually found in subsequent case that said ordinance was invalid because it violated state home-rule statute, Rooker-Feldman Doctrine required dismissal without prejudice of all but plaintiffs' deferral agreement-related claims since: (1) plaintiffs previously lost on said claims in state court; (2) their injuries flowed from final state-court judgments that imposed said fines; and (3) plaintiffs improperly sought in instant lawsuit to have federal Dist. Ct. review and reject said state-court judgments. As such, plaintiffs’ remedies for these claims lied only in state court. Rooker-Feldman Doctrine, though, did not apply to deferral agreement-related claims, since said agreements did not result in final state court judgment. However, dismissal with prejudice was warranted as to such claims since plaintiff failed to explain how deferral agreements violated any provision of U.S. Constitution.