James H. Hinkle v. Judge Stephanie Mingo

Summary

The United States District Court for the Southern District of Ohio overruled James H. Hinkle’s objection to a magistrate judge’s recommendation and dismissed his claims against Judge Stephanie Mingo. The court held that the claims were barred by the Rooker-Feldman doctrine and that Judge Mingo was entitled to absolute judicial immunity, even if she had acted in excess of her jurisdiction. The court warned Hinkle that continued repetitive or vexatious litigation could result in filing restrictions.

Holdings

1. Hinkle's claims were barred by the Rooker-Feldman doctrine because he sought to challenge the state-court decision on the basis that the state-court decision caused his injury, and he failed to object to the magistrate judge's recommendation on that ground.
2. Judge Mingo was entitled to absolute immunity from civil liability because the challenged conduct consisted of judicial functions performed within at least some subject-matter jurisdiction, even if she acted erroneously, maliciously, or in excess of her authority.
3. Hinkle could not amend his requested relief or obtain consideration of new issues raised for the first time in objections to the Report and Recommendation.

Questions Presented

1. Whether the district court should dismiss Hinkle's challenge to the state-court proceeding under the Rooker-Feldman doctrine.
2. Whether Judge Mingo was entitled to absolute judicial immunity where Hinkle alleged that she acted outside her jurisdiction over the particular property.
3. Whether Hinkle could raise new requests for disqualification and damages for the first time in objections to the magistrate judge's Report and Recommendation.

Disposition

dismissed