Marlon Turner v. Philadelphia County Domestic Relations, et al.

Summary

The United States District Court for the Eastern District of Pennsylvania granted Marlon Turner leave to proceed in forma pauperis but dismissed his 42 U.S.C. § 1983 action concerning child-support enforcement and wage garnishment. The court held that the Philadelphia and Cambria County Domestic Relations divisions are arms of Pennsylvania’s Unified Judicial System, are protected by Eleventh Amendment immunity, and are not persons subject to § 1983 liability. The court also concluded that Turner’s requested declaratory relief was improper and denied leave to amend as futile.

Holdings

1. Philadelphia County Domestic Relations and Cambria County Domestic Relations, as divisions of Pennsylvania's unified judicial system and arms of the Commonwealth, are not persons subject to liability under § 1983 and share in the Commonwealth's Eleventh Amendment immunity.
2. Declaratory relief is unavailable where it would merely adjudicate past conduct or proclaim that one party is liable to another, without defining legal rights in anticipation of future conduct.
3. Leave to amend was properly denied because amendment would be futile.

Questions Presented

1. Whether Turner stated a claim under 42 U.S.C. § 1983 against Philadelphia County Domestic Relations and Cambria County Domestic Relations.
2. Whether the named Pennsylvania domestic-relations entities are arms of the Commonwealth entitled to Eleventh Amendment immunity and therefore not persons subject to § 1983 liability.
3. Whether Turner could obtain declaratory relief concerning alleged past constitutional violations.
4. Whether amendment should be permitted.

Disposition

dismissed