Vacated Procedural Dismissals & Damages-Only Suits: Seventh Circuit Clarifies “Law-of-the-Case” and Rooker-Feldman in Williams v. City of Aurora

Introduction

In Andy Williams, Jr. v. City of Aurora, Illinois, the United States Court of Appeals for the Seventh Circuit confronted a sprawling civil-rights action springing from a routine traffic stop that led to a single guilty finding for a turn-signal violation. The plaintiff, Andy H. Williams, Jr., sued 25 municipal defendants under 42 U.S.C. § 1983 and Illinois’ Civil Rights Act, alleging an array of constitutional violations, racial profiling, malicious prosecution, maintenance of a gang database, and judicial bias. The district court dismissed most claims on jurisdictional grounds and ruled several others frivolous. On appeal, Williams challenged—among other things—the court’s reliance on the law-of-the-case doctrine and the Rooker-Feldman bar.

The Seventh Circuit affirmed but used the opportunity to sharpen two doctrinal boundaries:

• Law-of-the-Case: A dismissal based purely on procedural default, subsequently vacated, is not a “decision upon a rule of law” that binds later stages of the same litigation.
• Rooker-Feldman: Following its 2024 en banc decision in Gilbank v. Wood County, the Court reiterated that damages claims which do not seek to reverse a state-court judgment generally escape the jurisdictional bar—even when the plaintiff alleges fraud in obtaining that judgment.

Summary of the Judgment

Acting without oral argument, the panel (Judges Kirsch, Lee, and Kolar) systematically rejected each of Williams’s appellate arguments:

• Confirmed that Illinois trial courts possess subject-matter jurisdiction over state traffic offenses.
• Held that the traffic stop was supported by reasonable suspicion (validated by the eventual conviction) and that Williams failed to plead facts showing the stop was measurably prolonged.
• Clarified that the district court misapplied the law-of-the-case doctrine; nevertheless, de novo review showed the seizure claim still failed on the merits.
• Found Williams lacked Article III standing to challenge gang-related databases and statutes because he pled no actual or imminent injury.
• Explained that, under Gilbank, Rooker-Feldman did not bar a damages claim for alleged evidence fabrication, yet such a claim collapses absent custody or termination in the plaintiff’s favor as required by Manuel and Thompson.
• Dismissed judicial-bias allegations as speculative and insufficient to overcome the presumption of honesty and integrity.

The Court therefore affirmed the district court’s judgment in its entirety.

Analysis

A. Precedents Cited and Their Influence

• Gilbank v. Wood County Dep’t of Human Services, 111 F.4th 754 (7th Cir. 2024) (en banc)
  • Central to the Rooker-Feldman discussion. The panel applied Gilbank to confirm that requests for damages, as opposed to reversal or modification of state judgments, normally survive the jurisdictional bar.
• Arizona v. California, 460 U.S. 605 (1983)
  • Quoted for the standard formulation of the law-of-the-case doctrine: only a decided rule of law binds later stages.
• Musacchio v. United States, 577 U.S. 237 (2016)
  • Emphasized that law-of-the-case lets courts “refuse to reopen what has been decided,” underscoring why a vacated dismissal has no preclusive force.
• Whren v. United States, 517 U.S. 806 (1996) & United States v. Cole, 21 F.4th 421 (7th Cir. 2021)
  • Guided the Fourth-Amendment analysis of the traffic stop’s legality and duration.
• Puerto Rico v. Sánchez Valle, 579 U.S. 59 (2016) & Heath v. Alabama, 474 U.S. 82 (1985)
  • Rebutted Williams’s novel argument that state courts lack jurisdiction over state offenses.
• Manuel v. City of Joliet, 903 F.3d 667 (7th Cir. 2018) & Thompson v. Clark, 596 U.S. 36 (2022)
  • Established the elements of Fourth-Amendment malicious-prosecution claims—custody plus favorable termination—both missing here.

B. Legal Reasoning

1. Subject-Matter Jurisdiction of State Courts
   The panel swiftly dismissed Williams’s contention that Illinois courts lack power over state traffic offenses, invoking federalism principles preserved by the Tenth Amendment.
2. Reasonableness of the Traffic Stop
   • Officers possessed reasonable suspicion based on observed violations.
   • Even if the stop lasted “over an hour,” Williams failed to allege facts tying the duration to improper police conduct; sparse questioning alone is permissible under Arizona v. Johnson.
3. Law-of-the-Case Misapplication
   • Because the earlier dismissal was grounded in Williams’s failure to respond (procedural default) and was later vacated, it never became a controlling rule of law.
   • The appellate court therefore reviewed the seizure claim de novo—ultimately upholding dismissal on substantive grounds.
4. Standing to Challenge Gang Database & Statutes
   • Injury-in-fact requires concrete, particularized harm or imminent threat. Speculative fears of future harassment did not suffice.
5. Rooker-Feldman Scope Post-Gilbank
   • Damages claims that neither seek to overturn a conviction nor restate issues actually decided by the state court escape the doctrine.
   • Allegations of evidentiary fraud do not create a “fraud exception” to Rooker-Feldman; they are either barred (if relief would negate the judgment) or allowed (if relief is purely monetary).
6. Malicious-Prosecution Elements
   • No custody and no favorable termination = no viable § 1983 malicious-prosecution theory.
7. Judicial Bias
   • Past prosecution work, party affiliation, and adverse rulings do not, without more, establish constitutionally intolerable probability of bias.

C. Practical & Doctrinal Impact

• Sharper Rooker-Feldman Boundary. Litigants may pursue damages-only claims even when their allegations undermine the legitimacy of a prior state judgment—provided they do not seek reversal or declaratory invalidation. This clarification harmonizes Seventh Circuit practice with other circuits post-Skinner and Kougasian.
• Limits of Law-of-the-Case. District courts must distinguish between substantive legal rulings and vacated procedural orders when invoking the doctrine; appellate courts will not defer blindly to earlier procedural dismissals.
• Fourth-Amendment Pleading Standards. Plaintiffs challenging the duration of traffic stops must allege specific officer actions that measurably extended the seizure—vague time estimates and general complaints about questioning are insufficient.
• Standing in Database/Surveillance Challenges. The decision underscores that “chilling effect” cases (post-AFP Foundation v. Bonta) still require concrete factual assertions that the plaintiff altered conduct because of the challenged policy.

Complex Concepts Simplified

• Rooker-Feldman Doctrine: A narrow jurisdictional rule preventing federal district courts (and, indirectly, appellate courts reviewing them) from acting as courts of appeal over final state-court judgments. It bars claims that effectively require overturning a state decision—not all claims that relate to the same events.
• Law-of-the-Case: Once an appellate or trial court decides a legal issue, that decision generally binds later phases of the same case. Exceptions exist where the earlier ruling was interlocutory, clearly erroneous, or—crucially here—vacated.
• Reasonable Suspicion vs. Probable Cause: Reasonable suspicion (Terry standard) justifies brief investigative stops; probable cause justifies arrests or search warrants. A traffic violation, no matter how minor, supplies reasonable suspicion for a stop.
• Standing: The constitutional requirement that a plaintiff show (1) an injury in fact, (2) traceable to the defendant, and (3) likely redressable by a favorable decision.
• Malicious Prosecution under § 1983: In the Seventh Circuit post-Manuel, such a claim is viable only when (a) the plaintiff was held in custody without probable cause and (b) the criminal case ended favorably for the plaintiff.

Conclusion

Williams v. City of Aurora provides a cogent reminder that:

• Vacated procedural dismissals cannot form the basis of law-of-the-case.
• After Gilbank, damages-only claims generally dodge Rooker-Feldman, but plaintiffs must still plead viable constitutional violations.
• Fourth-Amendment and Article III pleading standards remain exacting: plaintiffs must allege concrete facts linking police conduct (or statutory schemes) to real, personal harm.

Although designated “Nonprecedential,” the opinion’s doctrinal clarifications will likely guide district courts within the Seventh Circuit when:

1. Evaluating whether dismissed—or vacated—orders constrain later rulings, and
2. Determining the precise reach of Rooker-Feldman when a plaintiff seeks damages after losing in state court.

In the broader legal tapestry, the decision fortifies litigants’ understanding of jurisdictional gateways and underscores the evidentiary rigor required to convert allegations of police misconduct into actionable federal claims.