Jaron Blue Butler v. Travis John Willey, et al.

Summary

A U.S. Magistrate Judge recommends dismissal of Jaron Blue Butler’s second amended civil-rights complaint concerning the removal of his children and termination of his parental rights in state court proceedings. The recommended decision concludes that the claims are barred by the Rooker-Feldman doctrine and, alternatively, fail to plead sufficient facts to state an actionable claim under 28 U.S.C. §§ 1915 and 1915A.

Holdings

1. The action was barred by the Rooker-Feldman doctrine because Plaintiff was a state-court loser seeking relief from, and effectively reversal of, the state-court order terminating his parental rights.
2. Even if Rooker-Feldman did not bar the action, the second amended complaint failed to state an actionable constitutional claim because its allegations were conclusory and lacked sufficient supporting facts.

Questions Presented

1. Whether the Rooker-Feldman doctrine barred the federal action because Plaintiff sought relief from a state-court order terminating his parental rights.
2. Whether the second amended complaint stated a plausible constitutional claim under the standards applicable to prisoner and in forma pauperis screening.

Disposition

other