U.S. Seventh Circuit - The FindLaw 7th Circuit Court of Appeals Opinion Summaries Blog

City Traffic Ordinance Claims Dismissed

When a judge says 'hodge-podge' to describe your complaint, you might have a problem.

But if the writing on the wall was not clear enough for the plaintiffs who sued to dispatch their traffic tickets, then the federal appeals court spelled it out for them in the end. Cases, dismissed.

"Although people raise an astonishing variety of claims in the federal courts of this country, the fact remains that there are limits on the subject-matter jurisdiction of those courts," Chief Judge Diane Wood wrote in Lennon v. City of Carmel, Indiana.

Jurisdictional Issue

The U.S. Seventh Circuit Court of Appeals said that federal courts are not authorized to review state-court decisions, unless Congress enables them.

"This is so even if one or all parties would like an answer from the federal court," the judges explained.

The case arose after certain motorists were stopped for traffic violations under a Carmel City Ordinance Section 8-2, which incorporated state traffic regulations. Some of the drivers admitted their offenses and paid fines, some suffered defaults for not appearing at hearings; others were convicted at trial; no one appealed.

Instead, they filed their complaint in federal court based on an unrelated case. In Maraman v. City of Carmel, a state appeals court ruled Carmel City Ordinance Section 8-2 was invalid under Indiana's Home Rule laws.

A State Problem

Even so, the federal court dismissed the Lennon case on several grounds. The Seventh Circuit affirmed.

"The legal status of the plaintiffs' state traffic judgments is a question for the Indiana courts," the panel said.

They said the claims were "too poorly developed" to state a claim and failed to demonstrate a constitutional issue. The problem went even deeper.

"[I]t pervades this entire lawsuit," the judges said. "We have yet to see anything that engages the federal constitution, as opposed to Indiana's internal allocation of responsibility for codes regulating traffic."

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