Gregory J. Van Etten v. Stephanie K. Fattman, et al.

Summary

The United States District Court for the District of Massachusetts reviews and largely adopts three reports and recommendations in Gregory J. Van Etten’s civil-rights action concerning state-court child-support proceedings and wage withholding. The court holds that the Rooker-Feldman doctrine and Eleventh Amendment immunity bar the claims, overrules the plaintiff’s objections, declines to reach alternative Rule 12(b)(6) grounds, and upholds striking the proposed amended complaint.

Holdings

1. A magistrate judge may issue a report and recommendation on a dispositive motion and rule on authorized nondispositive pretrial matters without the parties' consent; the district judge's initials in the case designation do not restrict that authority.
2. Plaintiff did not establish that the prior federal order was void under Rule 60(b)(4), because he did not show either a lack of subject-matter or personal jurisdiction or an exercise of judicial power so excessive as to violate due process.
3. The Rooker-Feldman doctrine deprived the district court of subject-matter jurisdiction because Plaintiff lost in state court and sought relief requiring the federal court to review, reject, invalidate, or effectively reverse the state-court judgments and related child-support orders.
4. The Eleventh Amendment barred Plaintiff's claims against the Probate Court and CSS-DOR and barred damages and retrospective relief against defendants sued in their official capacities; Plaintiff did not substantiate an applicable Ex parte Young exception.
5. The magistrate judge had authority to deny leave to amend and strike the proposed amended complaint, and those rulings were not clearly erroneous or contrary to law because Plaintiff failed to comply with procedural requirements and amendment would not cure the Rooker-Feldman jurisdictional defect.
6. Because the court lacked subject-matter jurisdiction under Rooker-Feldman and the Eleventh Amendment, it declined to reach the alternative Rule 12(b)(6) grounds for dismissal.

Questions Presented

1. Whether a magistrate judge may issue reports and recommendations on dispositive matters and decide nondispositive pretrial matters without the parties' consent.
2. Whether Plaintiff's Rule 60(b)(4) motion established that a prior federal order was void.
3. Whether the Rooker-Feldman doctrine deprived the district court of subject-matter jurisdiction over Plaintiff's constitutional claims challenging state-court judgments and their enforcement.
4. Whether the Eleventh Amendment barred claims against the Probate Court, CSS-DOR, and officials sued in their official capacities.
5. Whether the magistrate judge had authority to deny leave to amend and strike the proposed amended complaint.
6. Whether the court should reach Defendants' alternative Rule 12(b)(6) arguments after determining that subject-matter jurisdiction was lacking.

Disposition

dismissed