7th Circuit affirms dismissal of state-law claims against Carmel

The 7th Circuit Court of Appeals has affirmed the dismissal of a series of state-law complaints brought against the city of Carmel regarding the city’s traffic ordinance.

In upholding the decision, the federal appellate court noted the jurisidictional limits on federal courts to hear state-law claims

The case of Lawrence B. Lennon, et al. v. City of Carmel, Indiana, et al., 16-3836, began when the plaintiff motorists were stopped for traffic violations in Carmel. Each plaintiff was cited for violation of Carmel City Ordinance Section 8-2, which, at that time, adopted and incorporated the state of Indiana’s traffic regulations by referencing the portion of Indiana code defining motor vehicle infractions.

Some of the plaintiffs admitted to the offense and paid a fine; others did not appear at a hearing, so default judgment was entered against them. Additionally, other plaintiffs were convicted at a bench trial, while those remaining entered into an agreement that allowed them to pay a fine to avoid prosecution or conviction. None of the plaintiffs appealed the citations or judgment or challenged the deferral agreements in state court.

The plaintiffs instead filed an action in federal court after the Indiana Court of Appeals found Section 8-2 violated Indiana’s Home Rule laws in the unrelated case of Maraman v. City of Carmel, 47 N.E.3d 1218 (Ind. Ct. App. 2015), transfer denied, 48 N.E.3d 317 (Ind. 2016). In their federal action against a variety of local and state officials, the plaintiffs claimed the defendants violated U.S. Code Section 1983 through false or limited information about the traffic infractions, wrongful and improper ticketing, due process violations, excessive costs and unjust enrichment.

The plaintiffs sought damages and equitable relief in the federal court, including expungement of their traffic infractions and a stay of any BMV action in response to the judgments. The district court, however, dismissed the case on several grounds, including lack of standing, the Rooker-Feldman doctrine, and failure to state a claim upon which relief could be granted.

The plaintiffs appealed, but the 7th Circuit Court of Appeals on Tuesday upheld the district court’s decision. 

Chief Judge Diane Wood wrote, “The legal status of the plaintiffs’ state traffic judgments is a question for the Indiana courts.” Thus, the only claims that could survive the Rooker-Feldman doctrine are the “pre-adjudication claims” that allege injuries arising from the traffic stops that preceded and were unrelated to the traffic judgments, and those brought by plaintiffs who entered into deferral agreements.

Even among the claims that would survive Rooker-Feldman, Wood wrote the district court still should have dismissed the case because the plaintiffs failed to allege that any of the named defendants were personally involved in the traffic stops in question. Additionally, the pre-adjudication claims were too poorly developed to state a claim for relief, she noted.

The judges held the deferral agreement claims also fail because they do not explain how the agreements were misleading or unconstitutional.

“This failure to demonstrate a constitutional problem affects more than just the plaintiffs with deferral agreements,” Wood wrote. “Rather, it pervades this entire lawsuit. We have yet to see anything that engages the federal constitution, as opposed to Indiana’s internal allocation of responsibility for codes regulating traffic.”

The 7th Circuit modified the judgment to show all claims brought by plaintiffs except those subject to deferral agreements or in the pre-adjudication group are dismissed without prejudice, while the latter two groups were dismissed with prejudice.