Aliyah Monroe v. TIMOTHY McDOWELL

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted May 10, 2024*
Decided May 10, 2024
Before
FRANK H. EASTERBROOK, Circuit Judge
AMY J. ST. EVE, Circuit Judge
JOHN Z. LEE, Circuit Judge
No. 23-3040
ALIYAH MONROE,
Plaintiff-Appellant,
v.
TIMOTHY McDOWELL,
Defendant-Appellee.
Appeal from the United States District
Court for the Southern District of
Illinois.
No. 3:23-cv-02854-SPM
Stephen P. McGlynn,
Judge.
O R D E R
* The appellee was not served with process and is not participating in this appeal.
We have agreed to decide the case without oral argument because the appellant’s brief
and the record adequately present the facts and legal arguments, and oral argument
would not significantly aid the court. See 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NONPRECEDENTIAL DISPOSITION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. 23-3040 Page 2
A state court issued a child-custody decision that required Aliyah Monroe to
split custody with the child’s father. Monroe sued the father, invoking federal diversity
jurisdiction, 28 U.S.C. § 1332, and asked a federal district court to “vacate” the custody
decision. The court dismissed the case based on two limits to federal jurisdiction. The
first is the Rooker-Feldman doctrine, which bars federal district courts from hearing cases
brought by state-court losers who complain of injuries caused by state-court judgments
and seek review and rejection of those judgments. Exxon Mobil Corp. v. Saudi Basic Indus.
Corp., 544 U.S. 280, 283–84 (2005) (citing Rooker v. Fid. Tr. Co., 263 U.S. 413 (1923); D.C.
Ct. of Appeals v. Feldman, 460 U.S. 462 (1983)). The second is the domestic-relations
exception to federal diversity jurisdiction, which bars federal courts from adjudicating
“divorce, alimony, and child custody” matters. Ankenbrandt v. Richards, 504 U.S. 689, 703
(1992). Both rationales provide an independent basis for dismissal, and we affirm.
Monroe alleges the following, which we take as true for purposes of this appeal.
See Sherwood v. Marchiori, 76 F.4th 688, 693 (7th Cir. 2023). In 2018, Monroe and Timothy
McDowell had a child together in Illinois. Later, Monroe moved to Florida, and
McDowell moved to Missouri. After they had each left the state, an Illinois court
awarded split custody: It required that the parents exchange the child in Tennessee
(initially, every two weeks, but now every four weeks). The state court warned Monroe
that if she was found in contempt of the order, it would assign primary custody to
McDowell.
On appeal, Monroe argues that the district court had jurisdiction to overturn the
state court’s child-custody decision because, in her view, the state court lacked
jurisdiction over non-state residents. See 750 ILCS 36/202. But asking a federal district
court to redress a state court’s judgment—even one that is allegedly unauthorized
under state law—falls squarely within Rooker-Feldman’s prohibition. See Exxon Mobil
Corp., 544 U.S. at 284; Mains v. Citibank, N.A., 852 F.3d 669, 676 (7th Cir. 2017).
The domestic-relations exception to federal diversity jurisdiction, which Monroe
does not address on appeal, provides another basis for us to affirm. State courts have
“special proficiency” in handling child-custody decisions, Marshall v. Marshall, 547 U.S.
293, 308 (2006) (quoting Ankenbrandt, 504 U.S. at 704), and Monroe’s challenge to the
custody decision is blocked by the statutory-based exception to federal diversity
jurisdiction for custody disputes. See Arnold v. Villareal, 853 F.3d 384, 387 n.2 (7th Cir.
2017) (citing Friedlander v. Friedlander, 149 F.3d 739, 740–41 (7th Cir. 1998)).
AFFIRMED

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