Steven Craig Garfield v. Cathy Jezmans

Summary

The United States District Court for the District of Oregon grants Steven Craig Garfield’s application to proceed in forma pauperis but dismisses his civil-rights and Fair Housing Act claims concerning allegedly discriminatory living conditions and eviction. The Court holds that the claims are barred by claim preclusion, the Rooker-Feldman doctrine, and the statute of limitations, and that the complaint fails to state claims under 42 U.S.C. § 1983 or the Fair Housing Act. The dismissal is with leave to amend, and Garfield’s motion for appointment of counsel is denied.

Holdings

1. Claim preclusion barred Garfield from relitigating his claims against Jenman and McKinney because the claims had been finally adjudicated in the prior eviction proceeding, involved the same factual transaction, and McKinney was sufficiently in privity with the parties to that proceeding.
2. The district court lacked jurisdiction to review the Lane County Circuit Court's eviction judgment.
3. Garfield's Section 1983 and Fair Housing Act claims, as alleged, were barred by two-year statutes of limitations.
4. The complaint failed to state a claim under 42 U.S.C. § 1983 because it did not allege that Jenman or McKinney acted under color of state law.
5. The complaint failed to state a Fair Housing Act claim because its allegations did not establish that the Act applied to the dwelling or defendants.
6. Appointment of counsel was not warranted because exceptional circumstances did not exist.

Questions Presented

1. Whether Garfield's claims were barred by claim preclusion because the same claims or claims arising from the same transaction had been litigated in the prior eviction proceeding.
2. Whether the Rooker-Feldman doctrine deprived the federal district court of jurisdiction to review the state-court eviction judgment.
3. Whether the claims were barred by the applicable two-year statutes of limitations.
4. Whether the complaint stated a claim under 42 U.S.C. § 1983 against private defendants who were not alleged to have acted under color of state law.
5. Whether the complaint stated a claim under the Fair Housing Act where the alleged dwelling appeared to fall within the statutory exemption for certain owner-occupied dwellings.
6. Whether appointment of counsel was warranted based on exceptional circumstances.

Disposition

dismissed