Dominique Jamal Williams v. Ruth Anne Thorton

Summary

The United States District Court for the District of South Carolina adopts a magistrate judge’s Report and Recommendation and dismisses without prejudice a pro se plaintiff’s constitutional claims arising from child-support enforcement actions. The court concludes that the Rooker-Feldman doctrine deprives it of subject-matter jurisdiction and notes that no objections were filed.

Holdings

1. When no specific objections are filed, the district court is not required to conduct de novo review and need only determine whether the record contains clear error.
2. The district court lacks subject-matter jurisdiction under the Rooker-Feldman doctrine over claims that seek relief for injuries caused by state-court child-support determinations when resolving the claims would require the federal court to review or invalidate those state-court orders.

Questions Presented

1. Whether the district court should review the magistrate judge's Report and Recommendation for clear error when no specific objections were filed.
2. Whether the district court had subject-matter jurisdiction over a § 1983 action seeking relief from injuries allegedly caused by state child-support orders and related enforcement actions under the Rooker-Feldman doctrine.

Disposition

dismissed