Johnathan McFarland v. Hon. John F. Newsham

Summary

The United States District Court for the Eastern District of Missouri granted Johnathan McFarland leave to proceed in forma pauperis but dismissed his § 1983 action without prejudice. The court concluded that the claims concerning child custody and child support were barred by the domestic-relations exception and the Rooker-Feldman doctrine, and that the state court judge was entitled to absolute judicial immunity. The court also denied emergency injunctive relief as moot and certified that an appeal would not be taken in good faith.

Holdings

1. The federal district court lacked jurisdiction over claims that were inextricably intertwined with state-court determinations concerning child custody and child support; styling the claims as civil-rights claims did not alter their domestic-relations substance.
2. The district court lacked jurisdiction to review or reject the state-court judgment concerning Plaintiff's children because the claims could succeed only if the federal court determined that the state-court decision was wrong.
3. The state-court judge was entitled to absolute judicial immunity because Plaintiff's allegations concerned judicial actions and did not show that the judge acted in the complete absence of jurisdiction.
4. A complaint filed in forma pauperis must be dismissed under 28 U.S.C. § 1915(e)(2) when it is frivolous, malicious, fails to state a plausible claim, or is subject to dismissal for lack of jurisdiction or immunity.

Questions Presented

1. Whether the federal district court had subject-matter jurisdiction over claims seeking to alter or review state-court child-custody and child-support determinations.
2. Whether the domestic-relations exception and the Rooker-Feldman doctrine barred the federal claims.
3. Whether the state-court judge was entitled to absolute judicial immunity from claims arising from judicial conduct.
4. Whether the complaint should be dismissed on initial review under 28 U.S.C. § 1915(e)(2).

Disposition

dismissed