Subject-matter Jurisdiction

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7^th Circuit Court of Appeals

Case Name: Jose Andrade v. City of Hammond, Indiana, et al.,

Case No.: 20-1541

Officials: SYKES, Chief Judge, and FLAUM and KANNE, Circuit Judges.

Focus: Subject-matter Jurisdiction  

Appellate review of state-court judgments is reserved exclusively to the United States Supreme Court. The Rooker-Feldman doctrine provides the jurisdictional bar that prevents lower federal courts from improperly exercising such review. Federal cases involving claims that are “independent” from a state-court judgment, however, obviously fall outside of Rooker-Feldman’s purview.

In this case, Plaintiff Jose Andrade sued the City of Hammond, the Hammond Board of Public Works and Safety, and several Hammond employees for violating his due process rights when making an administrative determination regarding his rental property. Although the administrative determination was later affirmed by Indiana courts, Andrade’s claims concern Defendants’ actions separate from any state-court judgment. Thus, Rooker-Feldman does not bar federal-court jurisdiction. We accordingly reverse the contrary decision of the district court and remand this case for further proceedings.

Reversed and remanded

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Derek A Hawkins is Corporate Counsel, at Salesforce.