Melissa (Alyssa) Rollins v. Sharon Rollins, et al.

Summary

The United States District Court for the Middle District of Tennessee grants the pro se plaintiff leave to proceed in forma pauperis but dismisses her federal claims arising from state-court proceedings concerning ownership and sale of real property. The court holds that the claims seeking to block or invalidate state-court orders are barred by the Rooker-Feldman doctrine and alternatively fail to state claims under 42 U.S.C. §§ 1983, 1985(3), and 1986. The court declines supplemental jurisdiction over the state-law claims, denies the temporary restraining order as moot, and directs entry of judgment.

Holdings

1. The district court lacked subject-matter jurisdiction over Plaintiff's § 1983 claims insofar as they sought federal review, rejection, or injunction of the state-court judgments.
2. Alternatively, Plaintiff failed to state a viable § 1983 claim because she did not allege that DeKalb County's policy or custom caused a constitutional deprivation and did not adequately allege that the other defendants were state actors.
3. Plaintiff failed to state plausible claims under §§ 1985(3) and 1986 because she did not allege that the purported conspiracy was motivated by racial or class-based animus, and § 1986 liability depends on a viable § 1985 claim.
4. The court declined to exercise supplemental jurisdiction over Plaintiff's remaining state-law claims and dismissed them without prejudice.

Questions Presented

1. Whether the district court had subject-matter jurisdiction over Plaintiff's claims seeking to enjoin, block, or set aside DeKalb County Chancery Court orders.
2. Whether Plaintiff stated a plausible claim under 42 U.S.C. § 1983 against DeKalb County and the other defendants.
3. Whether Plaintiff stated a plausible conspiracy claim under 42 U.S.C. § 1985(3) and a derivative claim under 42 U.S.C. § 1986.
4. Whether the court should exercise supplemental jurisdiction over Plaintiff's state-law claims after dismissing all federal claims.
5. Whether Plaintiff's motion for a temporary restraining order remained justiciable after dismissal of the action.

Disposition

dismissed