John Raymond Bower v. Henry T. Reagan, II

Summary

The United States District Court for the Middle District of Alabama dismissed John Raymond Bower’s § 1983 action against an Alabama state-court judge without prejudice for lack of subject-matter jurisdiction. The court held that Bower’s constitutional challenges to a divorce judgment awarding custody and permitting relocation of the parties’ minor child to Saudi Arabia were barred by the Rooker-Feldman doctrine. The court denied his pending requests for injunctive relief as moot and permitted him to file an amended complaint addressing the jurisdictional defect.

Holdings

1. Rooker-Feldman barred Bower's Establishment Clause claim because the claim alleged injury caused by the state court's custody and relocation judgment and sought declaratory and injunctive relief that would require the federal district court to review and reject that judgment.
2. Rooker-Feldman barred Bower's substantive due process claim because the alleged constitutional injury was the state court's relocation judgment itself, and the requested declaratory relief would effectively nullify that judgment.
3. Rooker-Feldman barred Bower's procedural due process and Citizenship Clause claim because it alleged constitutional injury from the state court's relocation judgment and required the federal court to review and reject that judgment.
4. The complaint was dismissed without prejudice for lack of subject-matter jurisdiction under Rooker-Feldman; the motions for a temporary restraining order, preliminary injunction, and expedited review were denied as moot, and Bower was permitted to file an amended complaint curing the jurisdictional defect.

Questions Presented

1. Whether Rooker-Feldman barred Bower's First Amendment Establishment Clause claim challenging the state court's custody and relocation findings.
2. Whether Rooker-Feldman barred Bower's substantive due process claim alleging that the relocation provisions effectively terminated his parental rights without a finding of unfitness.
3. Whether Rooker-Feldman barred Bower's procedural due process and Citizenship Clause claim alleging that the relocation order effected the forced expatriation of a minor without adequate investigation.
4. Whether the complaint should be dismissed without prejudice for lack of subject-matter jurisdiction and whether the pending requests for injunctive relief should be denied as moot.

Disposition

dismissed