Aliyah Monroe v. Timothy McDowell, No. 23-3040 (7th Cir. 2024)

Annotate this Case
Download PDF
NONPRECEDENTIAL DISPOSITION To be cited only in accordance with FED. R. APP. P. 32.1 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, Appeal from the United States District Court for the Southern District of Illinois. v. No. 3:23-cv-02854-SPM TIMOTHY McDOWELL, Defendant-Appellee. Stephen P. McGlynn, Judge. ORDER 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 FED. R. APP. P. 34(a)(2)(C). * 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

Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.