Summary
The United States District Court for the Southern District of Indiana grants Donavan Ferguson leave to amend his complaint but dismisses the amended complaint. The court grants Industry Indianapolis's motion to dismiss based on claim preclusion and dismisses the claims against the other defendants for judicial immunity, insufficient factual allegations, lack of support for an access-to-courts claim, and failure to plead civil conspiracy. The court also denies motions for injunctive relief and appointment of counsel, and permits Ferguson until May 28, 2026, to show cause why final judgment should not issue.
Holdings
- Leave to amend should be freely granted when justice so requires, and plaintiff's motion to amend was granted.
- The Rooker-Feldman doctrine did not bar plaintiff's federal claims because his state-court appeal was still pending when he filed the federal action.
- Indiana claim-preclusion law barred plaintiff's claims against Industry Indianapolis because the prior small-claims judgment involved the same parties, was rendered by a court of competent jurisdiction on the merits, and concerned claims that were or could have been litigated in the prior action.
- The claims against Judges Roper and Strugill were dismissed because judicial officers are absolutely immune from suit for acts performed in their judicial capacities absent action in the complete absence of jurisdiction.
- The amended complaint failed to state plausible claims against the landlord employees, court personnel, unknown defendants, and alleged conspirators because it did not connect specific defendants to actionable conduct or plead a conspiratorial agreement.
- Plaintiff was not entitled to injunctive relief or appointed counsel at this stage.
Questions Presented
- Whether plaintiff should be granted leave to amend his complaint under Federal Rule of Civil Procedure 15(a)(2).
- Whether the Rooker-Feldman doctrine deprived the district court of subject-matter jurisdiction because plaintiff challenged a state-court eviction judgment.
- Whether Indiana claim-preclusion law barred plaintiff's claims against Industry Indianapolis based on the prior judgment on his state-court counterclaims.
- Whether the amended complaint stated plausible claims against the judges, landlord employees, court personnel, unknown defendants, and alleged conspirators.
- Whether plaintiff was entitled to preliminary injunctive relief or appointed counsel.
Disposition
dismissed
Cases Cited (39)
- Runnion v. Girl Scouts of Greater Chi. & Nw. Ind., 786 F.3d 510, 519-20 (7th Cir. 2015)(followed)
- Beal v. Beller, 847 F.3d 897, 901 (7th Cir. 2017)(followed)
- McCauley v. City of Chicago, 671 F.3d 611, 616 (7th Cir. 2012)(followed)
- Ctr. for Dermatology and Skin Cancer, Ltd. v. Burwell, 770 F.3d 586, 588-89 (7th Cir. 2014)(followed)
- Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)(followed)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)(followed)
- Bilek v. Fed. Ins. Co., 8 F.4th 581, 586 (7th Cir. 2021)(followed)
- Graham v. Bd. of Educ., 8 F.4th 625, 627 (7th Cir. 2021)(followed)
- Crawford v. Countrywide Home Loans, 647 F.3d 642, 645 (7th Cir. 2011)(followed)
- Parker v. Lyons, 757 F.3d 701, 705-06 (7th Cir. 2014)(followed)
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