Thomas E. Camarda v. Elizabeth M. Whitehorn

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted April 15, 2025*
Decided April 16, 2025
Before
THOMAS L. KIRSCH II, Circuit Judge
JOHN Z. LEE, Circuit Judge
NANCY L. MALDONADO, Circuit Judge
No. 24-3244
THOMAS E. CAMARDA,
Plaintiff-Appellant,
v.
ELIZABETH M. WHITEHORN, et al.,
Defendants-Appellees.
Appeal from the United States District
Court for the Northern District of Illinois,
Western Division.
No. 24 CV 50466
Iain D. Johnston,
Judge.
O R D E R
Thomas Camarda appeals the judgment dismissing his complaint (under
42 U.S.C. § 1983, challenging a state court’s child-support order) for lack of subject
* 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. FED. R. A PP. P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with FED. R. A PP. P. 32.1

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No. 24-3244 Page 2
matter jurisdiction. The district court concluded that it lacked subject matter jurisdiction
under the domestic-relations exception. We affirm.
Camarda brought this suit in federal court against the director of the Illinois
Department of Healthcare and Family Services (“DHFS”) and two DHFS employees
who oversaw his child-support case. The previous year, an Illinois state court had
ordered Camarda to pay child support to his ex-partner. See Bieber v. Camarda, No. 2022-
D-051802 (Ill. Cir. Ct. Aug. 25, 2023). In an amended complaint, he alleged that the
defendants, in their individual capacities, unlawfully seized his property by garnishing
and levying his bank accounts; deprived him of due process when they failed to
provide notice or a hearing before collecting his funds; fined him beyond constitutional
limitations; and retaliated against him for asserting his constitutional rights. He also
asserted numerous state-law claims, including intentional infliction of emotional
distress, unjust enrichment, and unlawful conversion of property. He sought damages
for financial harm, injunctive relief to avoid the levies, and declaratory relief to prevent
future collection attempts by DHFS officials.
The district court screened the amended complaint under 28 U.S.C. § 1915(e)(2)
and dismissed it for both lack of jurisdiction and failure to state a claim. The court
explained that the domestic-relations exception to federal jurisdiction stripped it of
jurisdiction to address Camarda’s claims concerning the state child-support
proceedings. Regardless, the court added, Camarda insufficiently alleged that the
defendants personally caused or participated in any constitutional violation. The court
relinquished supplemental jurisdiction over the remaining state-law claims.
See 28 U.S.C. § 1367(c)(3).
Camarda filed two post-judgment motions (one for reconsideration and one to
clarify the judgment), arguing that the court overlooked evidence of the defendants’
interference in his child-support case. The court denied both motions because Camarda
did not identify any reason to disturb its conclusion that it lacked jurisdiction or that he
failed to state a claim.
On appeal, Camarda challenges the dismissal of his amended complaint but does
not engage with the district court’s ruling that it lacked jurisdiction under the domestic-
relations exception. Under this exception, federal courts avoid deciding cases involving
particular domestic relations matters, see Marshall v. Marshall, 547 U.S. 293, 307–08
(2006), such as a decree of child support, see Friedlander v. Friedlander, 149 F.3d 739, 740
(7th Cir. 1998). State courts, which have developed procedures tailored to core domestic
relations matters, are presumed to be more proficient at handling such matters.

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No. 24-3244 Page 3
See Ankenbrandt v. Richards, 504 U.S. 689, 703–04 (1992); Struck v. Cook Cnty. Pub.
Guardian, 508 F.3d 858, 860 (7th Cir. 2007). We agree with the district court that the
exception applies here, given that the relief Camarda seeks—damages for financial
harm caused by the defendants’ collection of child support; injunctive relief to prevent
DHFS from collecting child support; and declaratory relief to prevent future
enforcement of the state-court proceedings—would encroach on the state court’s
adjudication of family law matters. See Struck, 508 F.3d at 859–60.
We close with two points. First, Camarda has filed over 100 motions and
supplemental filings in our court, even after we warned him—in four separate orders in
late 2024 and early 2025—that the barrage of filings could result in sanctions, revocation
of his electronic filing privileges, and submission without action from the court. App.
Doc. 45, 55, 64, 86; see also Support Sys. Int’l, Inc. v. Mack, 45 F.3d 185, 186 (7th Cir. 1995);
Cir. Operating Proc. R. 1(c)(8). Camarda is ordered to show cause within 14 days why
we should not impose sanctions, including fines and a filing bar under Mack, 45 F.3d
at 186, for his continued frivolous litigation after these warnings. Second, the district
court did not specify whether it dismissed Camarda’s claims with or without prejudice.
Because a dismissal for lack of jurisdiction is not on the merits, we modify the judgment
to reflect a dismissal without prejudice. See MAO-MSO Recovery II, LLC v. State Farm
Mut. Auto. Ins. Co., 935 F.3d 573, 581 (7th Cir. 2019).
As modified, the judgment is AFFIRMED.

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