Tom E. Hinkley v. John P. Hinkley; Gerald K. Johnson; Anthony R. Martineau; Jason W. Hardin; Sara Bouley; Judge Kara Pettit; City of West Jordan; Mayor Dirk Burton; Todd Zahlmann; West Jordan Police Department; and Does 1–10

Summary

The United States District Court for the District of Utah dismissed Tom E. Hinkley’s pro se civil-rights action without prejudice for lack of subject-matter jurisdiction. The court applied the Rooker-Feldman doctrine to claims related to a Utah probate and quiet-title proceeding and alternatively identified judicial immunity, lack of state action, pleading deficiencies, municipal-liability defects, frivolousness, and statute-of-limitations concerns.

Holdings

1. A federal district court lacks subject matter jurisdiction over claims seeking review or reversal of state-court judgments, including claims that are inextricably intertwined with those judgments.
2. A judge is generally immune from suits for damages and, under § 1983, injunctive relief, unless the judge acted outside the judge's judicial capacity or in the absence of all jurisdiction.
3. Private trustees and attorneys are not liable under § 1983 based solely on their participation in private litigation unless they acted under color of state law through joint activity with the State or its agents.
4. A municipality is not liable under § 1983 solely through respondeat superior; the plaintiff must identify a municipal policy or custom causing the constitutional violation, and an individual defendant must have personally participated in the alleged violation.

Questions Presented

1. Whether the Rooker-Feldman doctrine deprived the federal district court of subject matter jurisdiction over claims seeking to overturn or redress injuries caused by state-court probate and quiet-title judgments.
2. Whether claims against the state-court judge were barred by judicial immunity.
3. Whether the private trustees and attorneys could be liable under 42 U.S.C. § 1983 absent state action.
4. Whether the claims against the police department, municipality, mayor, and individual city official stated viable claims under § 1983.
5. Whether amendment would be futile because of jurisdictional defects, immunity, lack of state action, implausibility, and insufficient factual allegations.

Disposition

dismissed