MARCUS L. PECK v. FIRST TECHNOLOGY FEDERAL CREDIT UNION and AMERICAN INTERNATIONAL GROUP, INC
The Seventh Circuit vacated a district court dismissal of a consumer's federal claims against a creditor, ruling that the Rooker-Feldman doctrine does not bar suits alleging independent post-judgment debt collection misconduct. The appellate court held that claims regarding deceptive collection practices occurring after a state garnishment order are distinct from challenges to the state court's judgment itself.