Tomas v. Tribble - Dismissal for Lack of Subject Matter Jurisdiction
Summary
The U.S. District Court for the Northern District of Illinois dismissed the case of Tomas v. Tribble without prejudice for lack of subject matter jurisdiction. The court found that the plaintiff's claims regarding child support and participation in the Title IV-D program must be addressed in state court.
What changed
The U.S. District Court for the Northern District of Illinois, in the case of Tomas v. Tribble (Docket No. 1:25-cv-03000), has dismissed the plaintiff's lawsuit against Bryan Tribble, Administrator of the Division of Child Support Services of the Illinois Department of Healthcare and Family Services. The dismissal is without prejudice, citing a lack of subject matter jurisdiction. The court determined that the plaintiff's objections to child support collection and his claims regarding participation in the Title IV-D program are matters that must be pursued in state court.
This ruling means the federal court will not hear the case, and the plaintiff must refile or continue his claims within the state court system. Regulated entities, particularly state agencies involved in child support enforcement, should note that federal courts may decline jurisdiction over such matters, directing parties to state-level resolution. There are no immediate compliance actions required for other entities based on this specific ruling, as it pertains to jurisdictional issues in a single case.
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Feb. 24, 2026 Get Citation Alerts Download PDF Add Note
Tomas of the Family Savelskas v. Bryan Tribble, through the IV-D Agency
District Court, N.D. Illinois
- Citations: None known
- Docket Number: 1:25-cv-03000
Precedential Status: Unknown Status
Trial Court Document
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TOMAS OF THE FAMILY SAVELSKAS, )
)
Plaintiff, )
) No. 25 C 3000
v. )
) Judge Sara L. Ellis
BRYAN TRIBBLE, through the IV-D Agency, )
)
Defendant. )
ORDER
The Court grants Defendant Bryan Tribble’s motion to dismiss [11]. The Court dismisses
this case without prejudice for lack of subject matter jurisdiction. To the extent Plaintiff has any
claims against Defendant, he must proceed with them in state court. Case terminated. See
Statement.
STATEMENT
Plaintiff Tomas of the Family Savelskas filed this lawsuit against Bryan Tribble, the
Administrator of the Division of Child Support Services (“DCSS”) of the Illinois Department of
Healthcare and Family Services (“HFS”). Savelskas’ complaint stems from a divorce and child
custody case, in which a state court ordered him to pay child and spousal support. According to
an attachment to Savelskas’ complaint, Savelskas’ employer received a completed form
providing for withholding of income to comply with the support order. Savelskas objects to the
collection of child support and specifically DCSS’ alleged treatment of him as a non-custodial
parent subject to participation in the Title IV-D child support program. To that end, on February
17, 2025, Savelskas sent Tribble a notice to terminate Savelskas’ involuntary participation in the
Title IV-D program. DCSS responded to Savelskas’ letter, stating that DCSS was not “a party to
any enforcement or collection of support for the case [he] write[s] about” and so “would have no
knowledge nor information about the terms of [his] support order, payments, or account
balance.” Doc. 6 at 33. Savelskas nonetheless maintains that Tribble should have terminated
Savelskas’ participation in the Title IV-D program without awaiting any court order, and that his
refusal to do so violates Savelskas’ First, Fourth, Fifth, Seventh, Thirteenth, and Fourteenth
Amendment rights. Savelskas seeks termination of his involuntary participation in the Title IV-
D program, a refund of $19,615, the amount collected from him in child support at the time of
the filing of his complaint, and compensatory, punitive, and other damages.
Tribble has moved to dismiss Savelskas’ complaint pursuant to Federal Rules of Civil
Procedure 12(b)(1) and (b)(6). Savelskas attempts to distance his case from one involving
domestic relations and child support. See Doc. 6 at 1–2 (“[M]y claims are not related to a
Domestic Relation issue. This is not a matter regarding any IV-D order nor a paternity, custody,
or child support matter.” (citations omitted)). But he cannot escape such a characterization
merely by declaring it so. The domestic relations exception to federal subject matter jurisdiction
precludes federal courts from exercising jurisdiction over claims that implicate “the issuance of a
divorce, alimony, or child custody decree,” including, as here, Savelskas’ claims challenging
Tribble’s alleged enforcement of Savelskas’ child support obligations. Budorick v. Maneri, 697
F. App’x 876, 878 (7th Cir. 2017); see Camarda v. Whitehorn, No. 24-3244, 2025 WL 1121599,
at *1 (7th Cir. Apr. 16, 2025) (“[T]he [domestic relations] exception applies here, given that the
relief Camarda seeks—damages for financial harm caused by the defendants’ collection of child
support; injunctive relief to prevent DHFS from collecting child support; and declaratory relief to
prevent future enforcement of the state-court proceedings—would encroach on the state court’s
adjudication of family law matters.”); Dawaji v. Askar, 618 F. App’x 858, 860 (7th Cir. 2015)
(domestic relations exception to federal subject matter jurisdiction divested the court of
jurisdiction over child support claims); Rodriguez v. Lancaster Grant Cnty. Child Support
Agency, No. 24-cv-180, 2024 WL 3924576, at *2 (W.D. Wis. Aug. 23, 2024) (domestic relations
exception to federal jurisdiction applied to claim concerning collection of child support
obligations even despite plaintiff’s efforts to recast it as a due process violation); Liggins v. Ind.
Child Support Bureau, No. 3:18-CV-486, 2018 WL 4053402, at *1–2 (N.D. Ind. Aug. 24, 2018)
(court did not have subject matter jurisdiction over child support claims).
Further, even aside from the domestic relations exception, the Court would decline to
exercise jurisdiction in this case. Proceeding in federal court while child support proceedings
remain ongoing in state court would improperly “threaten interference with and disruption of
local family law proceedings.” J.B. v. Woodard, 997 F.3d 714, 723 (7th Cir. 2021). In other
words, Savelskas must pursue his grievances concerning the child support order in the state child
support proceedings, not in alternative venues that he may believe will prove more friendly to his
claims.
Date: February 24, 2026 /s/Sara L. Ellis_______________
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