Summary
The United States District Court for the Western District of Washington adopted a magistrate judge’s Report and Recommendation and dismissed Tremayne J. Reed’s 42 U.S.C. § 1983 action with prejudice. The court held that the complaint was an impermissible de facto appeal of a state-court restitution order barred by the Rooker-Feldman doctrine, resulting in a lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3).
Court
United States District Court for the Western District of Washington
Jurisdiction
United States District Court for the Western District of Washington
Decision date
January 23, 2026
Docket number
C25-5687-KKE
Disposition
dismissed
Questions Presented
- Whether the district court had subject matter jurisdiction over Reed's § 1983 action challenging a state-court restitution order.
- Whether the Rooker-Feldman doctrine barred the action as an impermissible de facto appeal from a state-court judgment.
- Whether Reed's objections showed that his action concerned an independent access-to-courts injury rather than an attempt to obtain relief from the state-court judgment.
Holdings
- The district court lacked subject matter jurisdiction because Reed's complaint sought federal review or relief from a state-court decision.
- The Rooker-Feldman doctrine is not limited to challenges to convictions or sentences; it also applies to a challenge to a state-court restitution order when the plaintiff seeks relief from that state-court decision.
Court Document
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