Lawson v. Dice Holdings LLC et al

UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
IMANI LAWSON,
Plaintiff,
v.
DICE HOLDINGS LLC,
OZARKS COMMUNITIES,
THERESA KNOTH, and
DANIEL,
Defendants.
Case No. 26-cv-00041-JPG
MEMORANDUM AND ORDER
This case is before the Court on Plaintiff Imani Lawson’s Motion for Leave to Proceed in
Forma Pauperis (Doc. 4). A federal court may permit an indigent party to proceed without pre-
payment of fees. 28 U.S.C. § 1915(a)(1). Nevertheless, a court can deny a qualified plaintiff
leave to file in forma pauperis or can dismiss a case if the action is clearly frivolous or malicious
or fails to state a claim. Id. § 1915(e)(2)(B)(i) & (ii). The test for determining if an action is
frivolous or without merit is whether the plaintiff can make a rational argument on the law or
facts in support of the claim. Neitzke v. Williams, 490 U.S. 319, 325 (1989); Corgain v. Miller,
708 F.2d 1241, 1247 (7th Cir. 1983). An action fails to state a claim if it does not plead “enough
facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S.
544, 570 (2007). When assessing a motion to proceed in forma pauperis, a district court should
inquire into the merits of the plaintiff’s claims, and if the court finds them to be frivolous, it
should deny leave to proceed in forma pauperis. Lucien v. Roegner, 682 F.2d 625, 626 (7th Cir.
1982).
The Court is satisfied from Plaintiff’s affidavit that she is indigent. However, it finds that
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it lacks jurisdiction over this case. It reaches this conclusion for two reasons. First, it believes
that it is barred from exercising jurisdiction under the Rooker-Feldman doctrine. The doctrine is
“based upon the recognition that lower federal courts do not have the power to exercise appellate
review over state court decisions.” Nationscredit Home Equity Servs. Corp. v. City of Chicago,
135 F. Supp. 2d 905, 908 (N.D. Ill. 2001). “Under Rooker-Feldman, lower federal courts lack
jurisdiction over claims seeking review of state court judgments or over claims that are
‘inextricably intertwined’ with state court determinations.” Id. at 908–09. To determine if the
doctrine applies, the Court “must determine whether the federal plaintiff seeks to set aside a state
court judgment or whether the plaintiff is, in fact, presenting an independent claim.” Id. at 909.
“[I]f the injury which the federal plaintiff alleges resulted from the state court judgment itself,
then Rooker-Feldman controls, and the lower federal courts lack jurisdiction over the claim. It
does not matter that the state court judgment might be erroneous or even unconstitutional.” 4901
Corp. v. Town of Cicero, 220 F.3d 522, 527–28 (7th Cir. 2000).
The Rooker-Feldman doctrine applies to this case. The injury alleged by Plaintiff appears
to have resulted from the state court eviction judgment. She states that, because of Defendants’
actions, she was left homeless, and she suffered property damage, emotional distress and
financial hardship. All these injuries are caused by the state court judgment. In other words, if
the state court had not approved the eviction, then Plaintiff would have no injury. Further,
Plaintiff explicitly asks this Court to vacate the eviction and related judgments. This Court has no
jurisdiction to reverse a state court judgment. Instead, “a party who seeks to overturn a state
court judgment must proceed through the state judicial system and can seek federal review only
from the United States Supreme Court.” Nationscredit Home Equity Servs. Corp., 135 F. Supp.
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2d at 909.
Second, Plaintiff fails to state any claim within the Court’s subject matter jurisdiction.
Plaintiff asserts federal question jurisdiction under 28 U.S.C. § 1331. Her complaint attempts to
allege violations of the Fair Housing Act (“FHA”). She claims that she notified Defendant
Theresa Knoth (“Knoth”) of discrepancies in her Ameren bills, and in retaliation for asserting her
rights, Knoth terminated her lease, engaged in unprofessional and harassing communications,
and initiated eviction proceedings. The FHA prohibits discrimination “in the terms, conditions,
or privileges of sale or rental of a dwelling, or in the provision of services or facilities in
connection therewith, because of race, color, religion, sex, familial status, or national origin.” 42
U.S.C. § 3604(b). In addition, it makes it unlawful “to coerce, intimidate, threaten, or interfere
with any person in the exercise or enjoyment of, or on account of his having exercised or
enjoyed, or on account of his having aided or encouraged any other person in the exercise or
enjoyment of, any right granted or protected by section 3603, 3604, 3605, or 3606 of this title.”
42 U.S.C. § 3617. Plaintiff fails to state a claim under the FHA. She has not alleged that she was
discriminated against based on any protected characteristic. In fact, she fails to even allege that
she is a member of a protected class. She also does not allege that she engaged in the exercise of
a protected activity under the FHA. Without a federal cause of action, this Court lacks subject
matter jurisdiction.
The Court is satisfied that Plaintiff is indigent but believes that it lacks subject matter
jurisdiction over this case. It ORDERS Plaintiff to SHOW CAUSE on or before April 3, 2026,
why the Court should not dismiss this case for lack of subject matter jurisdiction. In response to
this order to show cause, Plaintiff may file an amended complaint with sufficient facts to state a
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claim that arises under federal law and resulted in an injury not caused by or inextricably linked
to the state court eviction judgment. If Plaintiff fails to respond to this order to show cause, the
Court will dismiss this case for lack of subject matter jurisdiction. It RESERVES RULING on
Plaintiff Imani Lawson’s Motion for Leave to Proceed in Forma Pauperis (Doc. 4).
IT IS SO ORDERED.
DATED: March 4, 2025
s/ J. Phil Gilbert
J. PHIL GILBERT
United States District Judge
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