Jovan David Rebolledo Mendez v. Keely Marie Brandon

Summary

The United States District Court for the Western District of Kentucky denied Jovan David Rebolledo Mendez’s Rule 59(e) motion seeking to alter or vacate the dismissal of his petition for the return of children to Japan under the Hague Convention and ICARA. The court held that Mendez largely repeated arguments previously presented and failed to establish clear legal error or manifest injustice. The court also stated that it could not review the state court’s Hague judgment under the Rooker-Feldman doctrine and was required to give that judgment full faith and credit.

Holdings

1. A Rule 59(e) motion may not be used to relitigate matters or raise arguments that could have been presented before judgment; Mendez's repeated arguments therefore did not establish entitlement to relief.
2. Mendez failed to show that the court's prior decision to abstain under Younger and Colorado River represented a clear error of law.
3. The federal district court lacked jurisdiction to review or overturn the state-court Hague judgment under the Rooker-Feldman doctrine.
4. ICARA required the federal court to accord full faith and credit to the state-court judgment granting or denying return of a child under the Convention.
5. Mendez did not demonstrate a manifest injustice warranting Rule 59(e) relief.

Questions Presented

1. Whether Mendez satisfied the requirements for relief from the prior dismissal under Federal Rule of Civil Procedure 59(e).
2. Whether the court clearly erred by abstaining under Younger and Colorado River in light of the parallel state-court Hague proceeding.
3. Whether the federal court could overturn or review the state court's Hague judgment.
4. Whether ICARA required the federal court to give the state-court Hague judgment full faith and credit and preclusive effect.
5. Whether the prior abstention decision caused a manifest injustice warranting Rule 59(e) relief.

Disposition

other