Tanesha A. Turner v. 3526-28 E 9th Ave Trust, et al.

Summary

The United States District Court for the Northern District of Indiana granted motions to dismiss claims brought by a pro se plaintiff concerning housing assistance, alleged housing discrimination and retaliation under the Fair Housing Act, eviction proceedings, and related Indiana law claims. The court held that Rooker-Feldman barred FHA claims intertwined with the state-court eviction judgment and that the remaining 2020 FHA claims against Continuum of Care Network of Northwest Indiana, Dr. Sharron Liggins, and William Gillespie failed to state a claim. State-law claims were dismissed without prejudice, and the plaintiff was granted leave to amend certain FHA claims by March 26, 2026.

Holdings

1. The Rooker-Feldman doctrine bars federal jurisdiction over FHA claims alleging that eviction-related proceedings were retaliatory or discriminatory when resolving those claims would require reviewing or setting aside the state-court eviction judgment.
2. Rooker-Feldman does not bar independent FHA claims based on alleged discrimination or retaliation occurring before and separately from the state eviction case.
3. Turner's FHA discrimination claims failed under Rules 8 and 12(b)(6) because the complaint did not plausibly allege wrongful conduct by each defendant or facts connecting the alleged conduct to a protected characteristic.
4. Turner's FHA retaliation claims failed under Rules 8 and 12(b)(6) because she did not plausibly allege protected activity or a causal connection between protected activity and defendants' actions.
5. The court declined to exercise supplemental jurisdiction over Turner's Indiana-law claims after dismissing the federal claims.
6. The court permitted Turner to amend her FHA allegations concerning 2020 conduct by CoC, Liggins, and Gillespie, but denied leave to replead claims barred by Rooker-Feldman.

Questions Presented

1. Whether the Rooker-Feldman doctrine deprived the federal court of jurisdiction over Turner's FHA claims that challenged or were inextricably intertwined with the state eviction judgment.
2. Whether Turner's FHA discrimination allegations stated a plausible claim under Federal Rules of Civil Procedure 8 and 12(b)(6).
3. Whether Turner's FHA retaliation allegations plausibly alleged protected activity, an adverse action, and a causal connection.
4. Whether the court should exercise supplemental jurisdiction over the Indiana-law claims after dismissing all federal claims.
5. Whether Turner should receive leave to amend some of her FHA claims.

Disposition

other