Santoyo v. Rivera

CourtDistrict Court, N.D. Illinois
DecidedJune 23, 2025
Docket1:24-cv-01233
StatusUnknown

This text of Santoyo v. Rivera (Santoyo v. Rivera) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Santoyo v. Rivera, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

RUBEN SANTOYO,

Plaintiff, No. 24 CV 1233 v. Judge Manish S. Shah NELSON RIVERA, et al.,

Defendants.

MEMORANDUM OPINION AND ORDER

Plaintiff Ruben Santoyo was evicted in February 2023. He sues the Cook County Sheriff’s Department deputies and deputy-sergeant who were involved in his eviction for violations of the Fourth Amendment’s right against unreasonable searches and seizures, false imprisonment, due process, equal protection, negligence, and emotional distress. Defendants, Deputies Rivera, Evans, Rodriguez, Vargas, Davila, Gonsalves, Perry, Galbreath, and Perez-Soto, and Deputy-Sergeant Locasio, move to dismiss the complaint for lack of subject-matter jurisdiction and for failure to state a claim upon which relief can be granted. For the reasons discussed below, the motion to dismiss for failure to state a claim is granted. I. Legal Standards A complaint requires only “a short and plain statement” showing that the plaintiff is entitled to relief. Fed. R. Civ. P. 8(a)(2); Ashcroft v. Iqbal, 556 U.S. 662, 677–78 (2009). To survive a motion to dismiss under Fed. R. Civ. P. 12(b)(6), the plaintiff must allege facts that “allow[] the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. Although a plaintiff does not need to recite every detail related to their allegations,

they must “include enough facts to present ‘a story that holds together.’” Roldan v. Stroud, 52 F.4th 335, 339 (7th Cir. 2022) (quoting Reed v. Palmer, 906 F.3d 540, 548 (7th Cir. 2018)). “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements” are insufficient. Iqbal, 556 U.S. at 678. Federal Rule of Civil Procedure 12(b)(1) governs dismissals based on a lack of subject-matter jurisdiction. District courts lack jurisdiction to exercise appellate

jurisdiction over state-court judgments. Gilbank v. Wood Cnty. Dep’t of Hum. Servs., 111 F.4th 754, 765 (7th Cir. 2024) (en banc), cert. denied, 145 S. Ct. 1167 (2025). Under the Rooker-Feldman doctrine, I do not have jurisdiction to hear a claim that seeks to overturn a state court judgment. Id. The plaintiff bears the burden of establishing jurisdiction. Apex Digital, Inc. v. Sears, Roebuck & Co., 572 F.3d 440, 443 (7th Cir. 2009). At this stage, I accept all factual allegations in the complaint as true and draw

all reasonable inferences in the plaintiff’s favor. Iqbal, 556 U.S. at 678; Lee v. City of Chicago, 330 F.3d 456, 468 (7th Cir. 2003). II. Facts On February 14, 2023, plaintiff Ruben Santoyo was evicted, and defendants Cook County Sheriff’s Deputies Nelson Rivera, Derrick Evans, Mark Rodriguez, Elizabeth Vargas, Hector Davila, Savio Gonsalves, Perez-Soto, Roy Perry, and Renea Galbreath and Deputy-Sergeant Alex Locasio enforced the eviction order. [29] at 3.1 Santoyo alleges that a court stayed the eviction, but despite the stay, the eviction proceeded. [29] at 4. He also says he was not provided adequate notice or an

opportunity to contest the eviction in court. [29] at 4. Santoyo alleges that as a result of the eviction, his personal belongings were damaged and lost, causing emotional distress, including anxiety, fear, and humiliation. [29] at 4. Finally, Santoyo alleges the eviction was discriminatory “based on a remark made about his lack of a middle name.” [29] at 4. III. Analysis

A. Motion to Dismiss for Lack of Subject-Matter Jurisdiction A federal district court lacks jurisdiction in “cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.” Gilbank, 111 F.4th at 766 (quoting Exxon Mobil v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005)). The Rooker-Feldman doctrine is a limited doctrine. Id. at 765; id. at 792–93 (Kirsch, J. concurring in part and dissenting in part) (citing

Exxon Mobil, 544 U.S. at 291–92).2 It is applied on a “claim-by-claim basis.” Id. at 765.

1 Bracketed numbers refer to entries on the district court docket. Referenced page numbers are taken from the CM/ECF header placed at the top of filings. The facts are taken from plaintiff’s amended complaint, [29]. The court substituted Sheriff Tom Dart as a nominal defendant in plaintiff’s original complaint, for purposes of discovery. See [8]. Plaintiff’s amended complaint dropped Sheriff Dart as a defendant. [31]. The clerk shall terminate Dart as a defendant in the caption. 2 This portion of the Gilbank opinion is the majority opinion of the en banc Seventh Circuit. A majority of the court joined Parts I, II, III, V, VI, and VIII of Judge Hamilton’s opinion. A The doctrine has five elements: (1) the federal plaintiff was a state-court loser; (2) the state-court judgment was final before the federal proceedings began; (3) the state-court judgment caused the alleged injury underlying the federal claim; (4) the

federal claim asks the federal district court to review and reject the state-court judgment; and (5) the plaintiff did not have a reasonable opportunity to raise his federal issues in the state courts. Id. at 766. Under the fourth element, a federal claim must seek to “undo” or “overturn” the state-court judgment. Id. at 791–93 (Kirsh, J., concurring in part and dissenting in part). Claims for damages do not generally “seek to undo any state court judgment.” Id. at 791–92 (“[A]warding damages usually does

not affect a state court judgment not sounding in monetary terms.”). While awarding damages for a federal claim “might result in a federal court frowning upon the state court’s conclusions … that is decidedly not a Rooker-Feldman problem.” Id. at 791. In short, a party who loses in state court may raise “precisely the same legal issues in federal court, so long as the relief sought in the federal action would not reverse or undo the relief granted by the state court.” Id. at 794 (emphasis in original) (quoting Mo’s Express, LLC v. Sopkin, 441 F.3d 1229, 1237 (10th Cir. 2006)).

Santoyo seeks damages for the alleged violations of constitutional and state law. [29] at 5. The relief granted in the state court was an order of eviction. [52-1] at 21–22. In the state court, Santoyo sought to vacate the judgment and stay the eviction proceedings, both of which were denied by the Circuit Court of Cook County. [52-1]

majority of the court joined Part I of Judge Kirsch’s concurrence in part, dissent in part (from which Judge Hamilton dissented in Part IV of his opinion). at 23–26. The Illinois Appellate Court, First District, denied three of Santoyo’s emergency motions to stay the eviction. [52-1] at 32–34. In his federal complaint, Santoyo does not seek to undo the order of eviction.

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Santoyo v. Rivera, Counsel Stack Legal Research, https://law.counselstack.com/opinion/santoyo-v-rivera-ilnd-2025.