McDonald v. Adamson
840 F.3d 343 · U.S. Court of Appeals, Seventh Circuit · 2016-10-17
Holding
The Illinois Court of Claims lacks jurisdiction over claims based on federal statutes or constitutions, so a prisoner's prior Court of Claims damages action did not preclude his federal section 1983 injunctive suit (defendants conceded no res judicata bar).
Context
Inmate filed parallel COC damages and federal injunctive actions over religious exercise. The Seventh Circuit reversed dismissal of the federal suit, establishing the boundary from the federal side: constitutional and federal-statutory claims cannot be heard in the Court of Claims.
federal claimsres judicatalimits of COC jurisdiction
Full opinion text (public domain): https://openjurist.org/840/f3d/343/mcdonald-v-adamson