United States v. Historic Fairmont Neighborhood Association, Inc.

CourtDistrict Court, N.D. Indiana
DecidedApril 29, 2025
Docket1:23-cv-00297
StatusUnknown

This text of United States v. Historic Fairmont Neighborhood Association, Inc. (United States v. Historic Fairmont Neighborhood Association, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Historic Fairmont Neighborhood Association, Inc., (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

PATRICK H MCDONALD,

Plaintiff,

v. Case No. 1:23-CV-297-CCB-SLC

HISTORIC FAIRMONT NEIGHBORHOOD ASSOCIATION, INC.,

Defendant.

OPINION AND ORDER Before the Court is Defendant Historic Fairmont Neighborhood Association, Inc.’s Motion to Dismiss (ECF 21) Plaintiff Patrick Henry McDonald’s Amended Complaint. (ECF 9). Based on the applicable law, facts, and arguments, Defendant’s Motion to Dismiss for Lack of Subject Matter Jurisdiction is GRANTED. I. RELEVANT BACKGROUND Plaintiff is a Fort Wayne resident. (ECF 10 at 1). In 2021, Plaintiff attempted to run for an open Vice President position in the Historic Fairmont Neighborhood Association (“HFNA”), a local non-profit organization of which he was a member. (Id. at 1, 2). Certain HFNA board members “conspired to ‘rig’ the election process so he [McDonald] ‘would not rise to power,’” but Plaintiff was elected to the Board of Directors nonetheless, just not as Vice President. (Id. at 2) (ECF 22 at 5). Plaintiff filed a civil complaint in the Allen County Superior Court on February 25, 2021. (Id.). In June 2022, the court granted Defendant’s Motion for Summary Judgment and awarded Defendant $10,000 in attorney fees and costs. (Id. at 4). Plaintiff appealed the Allen County Court’s decision to the Indiana Court of Appeals in July

2022. Patrick Henry McDonald v. The Historic Fairmont Neighborhood Ass’n Inc., 02D03- 2102-PL-000085. In January 2023, the Court of Appeals dismissed Plaintiff’s appeal with prejudice. Id. Plaintiff filed a Qui Tam complaint in federal court on July 17, 2023. (ECF 1). On August 24, 2023, the Court stayed the case until Plaintiff retained counsel. (ECF 6). Instead, Plaintiff filed an amended complaint on October 4, 2023, alleging Defendant

engaged in fraud in obtaining the state court judgment against him. (ECF 9). Defendant filed the instant motion to dismiss under Fed. R. Civ. P. 12(b)(1) asserting that the Court lacks subject matter jurisdiction. (ECF 21). II. STANDARD Federal Rule of Civil Procedure 12(b)(1) authorizes parties to seek dismissal of

cases for lack of subject matter jurisdiction. The parties asserting jurisdiction—in this case, Plaintiff—have the burden of proof to show that the court has subject matter jurisdiction. United Phosphorus, Ltd. v. Angus Chem. Co., 322 F.3d 942, 946 (7th Cir. 2003), overruled on other grounds by Minn-Chem, Inc. v. Agrium, Inc., 683 F.3d 845 (7th Cir. 2012). Rule 12(b)(1) motions to dismiss are evaluated differently depending on their purpose.

Apex Digit., Inc. v. Sears, Roebuck & Co., 572 F.3d 440, 443-44 (7th Cir. 2009). “If subject matter jurisdiction is not evident on the face of the complaint, the motion to dismiss pursuant to Rule 12(b)(1) would be analyzed as any other motion to dismiss, by assuming for purposes of the motion that the allegations in the complaint are true.” United Phosphorus, 322 F.3d at 946. A factual challenge to the court’s subject matter jurisdiction, on the other hand, is based on the assertion that “the complaint is formally

sufficient but . . . there is in fact no subject matter jurisdiction.” Id. (emphasis in original). When considering a factual challenge to the court’s jurisdiction, “[t]he district court may properly look beyond the jurisdictional allegations of the complaint and view whatever evidence has been submitted on the issue to determine whether in fact subject matter jurisdiction exists.” Evers v. Astrue, 536 F.3d 651, 656-57 (7th Cir. 2008) (quoting St. John’s United Church of Christ v. City of Chi., 502 F.3d 616, 625 (7th Cir. 2007)). Here,

Defendant argues that there is in fact no subject matter jurisdiction. Thus, the Court will consider all the evidence submitted related to subject matter jurisdiction. III. ANALYSIS Defendant argues that the Court lacks jurisdiction to review Plaintiff’s claim under the Rooker-Feldman doctrine. Plaintiff argues, on the other hand, that the fraud

exception to the doctrine applies here, or in the alternative, that he brings an independent claim, and therefore the Rooker-Feldman doctrine does not bar the Court from exercising jurisdiction. The Court agrees with Defendant. The Rooker-Feldman doctrine prevents lower federal courts from exercising jurisdiction over cases brought by “state-court losers complaining of injuries caused by

state-court judgments rendered before the district court proceeding commenced and inviting district court review and rejection of those judgments.” Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284-85 (2005). “To determine whether Rooker- Feldman bars a claim, we look beyond the four corners of the complaint to discern the actual injury claimed by the plaintiff.” Johnson v. Orr, 551 F.3d 564, 568 (7th Cir. 2008) (emphasis in original) (citation omitted) (explaining that it is “of no consequence” that

the complaint does not specifically challenge the state court order). A plaintiff “cannot avoid the Rooker-Feldman bar by alleging that he suffered this injury as a result of violations of his constitutional rights.” Id. Courts apply a two-step analysis to determine whether the Rooker-Feldman doctrine bars jurisdiction. Andrade v. City of Hammond, 9 F.4th 947, 950 (7th Cir. 2021). First, courts consider whether the plaintiff’s claims are “independent” or whether the

claims directly challenge a state court judgment or are “inextricably intertwined” with one. Swartz v. Heartland Equine Rescue, 940 F.3d 387, 391 (7th Cir. 2019). Then, courts determine whether “the plaintiff had a reasonable opportunity to raise the issue in state court proceedings.” Jakupovic v. Curran, 850 F.3d 898, 902 (7th Cir. 2017). If there is no way for the injury complained of to be separated from the state court judgment, or if

plaintiff did have a reasonable opportunity to raise the issue, then the claim is barred. Id. Plaintiff here directly challenges the state court judgment, asking the Court to “review the State level Judgment(s) which McDonald alleges were procured through fraud.” (ECF 9 at 1). Plaintiff also argues that “a civil judgment obtained by fraud is a

nullity and should be treated as such by any court,” meaning “that a judgment obtained by fraud is not a judgment, even if it appears to be one.” (ECF 10 at 7) (emphasis omitted). Plaintiff alleges that the state court judgment against him, including the $10,000 of attorney’s fees and costs, was allegedly obtained by fraud and constitutes the injury complained of. Plaintiff’s claims, then, are not independent of the state court judgment itself and there is no need to proceed to the second step of the analysis

because the claims are barred by the Rooker-Feldman doctrine.

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Related

Rooker v. Fidelity Trust Co.
263 U.S. 413 (Supreme Court, 1924)
District of Columbia Court of Appeals v. Feldman
460 U.S. 462 (Supreme Court, 1983)
Exxon Mobil Corp. v. Saudi Basic Industries Corp.
544 U.S. 280 (Supreme Court, 2005)
Minn-Chem, Incorpora v. Agrium Inco
683 F.3d 845 (Seventh Circuit, 2012)
St. John's United Church of Christ v. City of Chicago
502 F.3d 616 (Seventh Circuit, 2007)
Evers v. Astrue
536 F.3d 651 (Seventh Circuit, 2008)
Apex Digital, Inc. v. Sears, Roebuck & Co.
572 F.3d 440 (Seventh Circuit, 2009)
Johnson v. Orr
551 F.3d 564 (Seventh Circuit, 2008)
Mir Iqbal v. Tejaskumar Patel
780 F.3d 728 (Seventh Circuit, 2015)
Jamie Swartz v. Heartland Equine Rescue
940 F.3d 387 (Seventh Circuit, 2019)
Jose Andrade v. Hammond Board of Public Works
9 F.4th 947 (Seventh Circuit, 2021)
Jakupovic v. Curran
850 F.3d 898 (Seventh Circuit, 2017)
Mains v. Citibank, N.A.
852 F.3d 669 (Seventh Circuit, 2017)

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United States v. Historic Fairmont Neighborhood Association, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-historic-fairmont-neighborhood-association-inc-innd-2025.