Federal Appellate Court Denies Tenured Teacher's Due Process Claims As an Impermissible Attack on State Appellate Court's Decision

The Seventh Circuit Court of Appeals upheld the district court's dismissal of a tenured teacher's due process claims on the grounds that lower federal courts may not review the state court decisions in civil cases. The doctrine, referred to as the Rooker-Feldman doctrine, bars jurisdiction unless the claim rests on grounds independent of state court proceedings. As a result of the decision, the teacher was not permitted to reconvene his ISBE hearing, which ended before he had a chance to present evidence.

The plaintiff, a tenured teacher for Township High School District 211, challenged the district's decision to terminate him by invoking his right to a state administrative hearing before the ISBE.  Plaintiff was entitled to present witnesses and evidence under section 24-12 of the School Code. However, before presenting his case, plaintiff filed a motion for "judgment in his favor." The hearing officer granted the motion and ordered reinstatement.  The Circuit Court of Cook County affirmed. The Illinois Appellate Court reversed and remanded the case to the circuit court ordering immediate termination.  Following the appellate court's decision, the circuit court issued an order of termination.

After unsuccessfully filing for review by the Illinois Supreme Court, the plaintiff filed suit in federal district court on the grounds that the order violated his due process rights by not allowing him to reconvene the termination hearing.  The district court dismissed the case, holding it lacked jurisdiction under the Rooker-Feldman doctrine.

The Seventh Circuit affirmed, rejecting plaintiff's argument that the state circuit court and federal district court erred in assuming the Illinois appellate court meant to preclude further proceedings.  It noted that the plaintiff should have sought clarification from the state appellate court itself, not the federal court.