Theodore Sabir v. Joy Sabir

Summary

The United States District Court for the Middle District of Alabama dismissed Theodore Sabir’s amended complaint challenging a state-court divorce judgment. The court held that all three constitutional claims were barred by the Rooker-Feldman doctrine because resolving them would require review and rejection of the state-court judgment. The dismissal was without prejudice for lack of subject matter jurisdiction.

Holdings

1. The Rooker-Feldman doctrine barred the plaintiff's claims because they were claims that the state-court divorce judgment itself caused his alleged constitutional injuries and required the federal district court to review and reject that judgment. The district court therefore lacked subject matter jurisdiction.
2. The procedural due process claim based on the state court's alleged miscalculation of the plaintiff's income was barred by Rooker-Feldman.
3. The equal protection claim was barred by Rooker-Feldman because resolving it would require the district court to review and reject the state-court divorce judgment.
4. The claim that the state court violated the plaintiff's due process right to a neutral tribunal was barred by Rooker-Feldman.

Questions Presented

1. Whether the district court had subject matter jurisdiction over constitutional claims under 42 U.S.C. § 1983 that sought review, vacatur, or amendment of a state-court divorce judgment.
2. Whether the plaintiff's procedural due process, equal protection, and neutral-tribunal claims were barred by the Rooker-Feldman doctrine.
3. Whether the plaintiff's objections to the magistrate judge's recommendation should be overruled and the amended complaint dismissed without prejudice.

Disposition

dismissed