Johnathan McFarland v. Hon. John F. Newsham

Summary

The United States District Court for the Eastern District of Missouri denied Johnathan McFarland’s motions for reconsideration and emergency protective relief following dismissal of his action against a Missouri state court judge. The court held that McFarland could not establish a federal claim through post-dismissal supplements and that the sole defendant was immune from liability under 42 U.S.C. § 1983. The court also directed the Clerk to return any further filings in the closed case unfiled.

Holdings

1. Post-complaint supplements and letters cannot cure defects in the complaint; the complaint itself is the pleading reviewed to determine whether the plaintiff has stated a claim and established subject-matter jurisdiction.
2. Rule 59(e) relief was unavailable because McFarland did not show a substantive judicial error or mistake affecting the correctness of the judgment.
3. Because the case had been dismissed and the court lacked subject-matter jurisdiction, the court had no authority to provide the requested relief concerning the child-custody dispute.
4. The Clerk was directed to return any additional documents submitted by McFarland in the closed civil case unfiled because the post-dismissal filings were frivolous and repetitive.

Questions Presented

1. Whether McFarland was entitled to relief under Federal Rule of Civil Procedure 59(e) based on alleged federal claims presented in post-dismissal supplements and letters.
2. Whether post-complaint filings could cure the complaint's failure to establish subject-matter jurisdiction and state a claim against a defendant subject to liability under 42 U.S.C. § 1983.
3. Whether the district court could provide relief concerning injuries arising from the state child-custody proceedings after dismissing the action for lack of jurisdiction.
4. Whether the Clerk could be directed to return further filings in the closed case unfiled.

Disposition

other