Nathan John Huiras v. NICOLE HUIRAS and WISCONSIN DEPARTMENT OF CHILDREN AND FAMILIES

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted August 18, 2026*
Decided August 18, 2026
Before
MICHAEL B. BRENNAN, Chief Judge
AMY J. ST. EVE, Circuit Judge
JOHN Z. LEE, Circuit Judge
No. 25-3247
NATHAN JOHN HUIRAS,
Plaintiff-Appellant,
v.
NICOLE HUIRAS and WISCONSIN
DEPARTMENT OF CHILDREN AND
FAMILIES,
Defendants-Appellees.
Appeal from the United States District
Court for the Eastern District of
Wisconsin.
No. 25-CV-1416-JPS
J. P. Stadtmueller
Judge.
* The appellees were not served with process and are not participating in this
appeal. We have agreed to decide the case without oral argument because the brief and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 25-3247 Page 2
O R D E R
Nathan Huiras, seeking to modify his child support obligations, removed his
state divorce proceedings to federal court. The district court remanded the case for lack
of jurisdiction and imposed a five-year filing bar to sanction Huiras for his history of
frivolous federal litigation. We dismiss Huiras’s appeal of the remand order for lack of
appellate jurisdiction, and we affirm the sanction.
The state court that adjudicated Huiras’s divorce awarded his ex-wife custody of
their children and ordered Huiras to pay child support. Huiras has unsuccessfully
attempted to challenge those proceedings in federal court many times. See, e.g., Huiras v.
Huiras, No. 25-1861 (7th Cir. Jul. 21, 2025); In re Huiras, No. 25-1415 (7th Cir. Mar. 31,
2025); Huiras v. Cafferty, No. 23-1385, 2023 WL 6566492 (7th Cir. Oct. 10, 2023); Huiras v.
Cafferty, No. 22-3081, 2023 WL 4842323 (7th Cir. Jul. 28, 2023).
In 2025, after failing to persuade the state court to modify the child support
order, Huiras removed the divorce proceedings to federal court, asserting diversity
jurisdiction. See 28 U.S.C. §§ 1332(a), 1441(a). A magistrate judge recommended
remanding the case to state court because Huiras did not sufficiently allege diversity
jurisdiction and, alternatively, the domestic-relations exception to federal jurisdiction
applied. The district judge adopted the report and recommendation and issued a
judgment dismissing the case. The judge also imposed a filing bar, subject to
modification or recission after five years, to sanction Huiras for his repeated and
frivolous attempts to litigate family law disputes in federal court.
On appeal, Huiras challenges the district court’s jurisdictional determination. But
we lack appellate jurisdiction to review a remand order based on a jurisdictional defect.
28 U.S.C. § 1447(d); Kircher v. Putnam Funds Tr., 547 U.S. 633, 640 (2006). The district
court’s final order and judgment incorrectly dismissed the case, but we understand it to
have adopted the magistrate judge’s recommendation. So we construe the order to have
remanded the proceedings back to state court for lack of jurisdiction, as required under
28 U.S.C. § 1447(c). See Thompson v. Army & Air Force Exch. Serv., 125 F.4th 831, 836 (7th
Cir. 2025) (“Section 1447(c) requires federal courts to remand cases where they lack
subject matter jurisdiction.”).
We can, however, review the district court’s imposition of sanctions,
see Micrometl Corp. v. Tranzact Techs., Inc., 656 F.3d 467, 469–70 (7th Cir. 2011), which
Huiras also challenges. Huiras argues that the five-year filing bar is overly broad. We
review the court’s chosen sanction for abuse of discretion, Martin v. Redden, 34 F.4th 564,

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No. 25-3247 Page 3
568 (7th Cir. 2022), and here the court’s exercise of its discretion was sound. The court
explained that Huiras had abused the judicial system by repeatedly attempting to
litigate his family law disputes in federal court despite multiple judges’ rejections of his
claims, and the filing bar is tailored to curb that abuse. See Support Sys. Int’l, Inc. v. Mack,
45 F.3d 185, 186 (7th Cir. 1995). We add our own warning to Huiras that further
frivolous filings in this circuit may result in other sanctions including a fine and a
circuit-wide filing bar. See id. at 186–87.
We DISMISS the appeal of the district court’s remand order and AFFIRM its
imposition of a filing bar.

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