Summary
The Sixth Circuit held that the Rooker-Feldman doctrine did not bar § 1983 due process claims against Shelby County and its Environmental Court because the plaintiffs sought damages and declaratory relief for litigation expenses and missing case files—injuries stemming from court procedures, not from state-court judgments—and did not seek review or rejection of those judgments. The court also held that the Environmental Court is not a "person" under § 1983 because it is an arm of the state, not a body politic or corporate, and thus cannot be sued under the statute. The district court's dismissal for lack of jurisdiction was reversed, its dismissal of claims against the Environmental Court was affirmed, and the failure-to-state-a-claim ruling against the County was remanded for further consideration of Monell liability.
Topics
Practice areas
Questions Presented
- Whether the district court had jurisdiction under 28 U.S.C. § 1257(a) and the Rooker-Feldman doctrine to hear the plaintiffs' § 1983 claims.
- Whether the Environmental Court is a 'person' subject to suit under § 1983.
Holdings
- The Rooker-Feldman doctrine does not bar the action because the plaintiffs' injuries do not stem from state-court judgments and they do not seek review and rejection of those judgments.
- The Environmental Court is not a 'person' under § 1983 because it is an arm of the State of Tennessee, not a body politic or corporate.
Key quotations
“cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.” (Page 4)
“That is an 'exceedingly narrow' limitation on the jurisdiction of district courts, rarely relevant beyond the unusual fact patterns involving Rooker and Feldman.” (Page 4)
Factual background
Sarah Hohenberg and Joseph Hanson owned homes in Memphis, Tennessee, and failed to maintain them. Hohenberg did not repair a tree-damaged roof; Hanson allowed overgrowth and debris. Neighbors complained, leading to enforcement actions in the Shelby County Environmental Court. The court declared Hohenberg's home a public nuisance, appointed a receiver, and ordered a sale. Hohenberg left for Mississippi and filed for bankruptcy. Hanson was found guilty of code violations, held in contempt, and jailed; his house was bulldozed. Both cases were dismissed as moot.
Procedural history
The district court dismissed the plaintiffs' complaint for lack of jurisdiction under the Rooker-Feldman doctrine and for failure to state a claim. The plaintiffs appealed.
Remand instructions
The district court should consider the County's arguments that the plaintiffs have not pleaded a plausible § 1983 claim against it.