Davis v. Shepard

Summary

The United States District Court for the Eastern District of California adopted the magistrate judge’s findings and recommendations and dismissed Eric Davon Davis’s action without prejudice for lack of subject matter jurisdiction. The court held that Davis’s challenge to state child-support orders was barred by the Rooker-Feldman doctrine and the domestic-relations exception, and that claims against certain defendants were also barred by judicial immunity. The court denied Davis’s motions for preliminary injunction, default judgment, and immediate ruling as moot and directed the clerk to close the case.

Holdings

1. The claims were barred because they sought to challenge a state-court order requiring plaintiff to make child-support payments; the court therefore lacked subject matter jurisdiction.
2. The claims against Commissioner Shepard and Judge Badiga were barred by judicial immunity.
3. A court cannot enter a valid default judgment when it lacks subject matter jurisdiction, so denial of plaintiff's motion for default judgment as moot was proper.
4. Disagreement with the court's rulings does not establish bias; an assertion of bias must be based on an extrajudicial source.

Questions Presented

1. Whether the complaint challenging enforcement of state child-support orders was barred by the Rooker-Feldman doctrine and the domestic-relations exception.
2. Whether the court could enter default judgment when it lacked subject matter jurisdiction.
3. Whether plaintiff's disagreement with the magistrate judge's rulings established judicial bias.
4. Whether the magistrate judge's findings and recommendations should be adopted after de novo review.

Disposition

dismissed