Alexander v. Rosen, 804 F.3d 1203

Background

Plaintiff William Alexander sued a federal judge, a Michigan family court judge, and several state employees alleging a conspiracy to impose unlawful child support, provide false IRS information, and extort money.
He asserted federal RICO claims (18 U.S.C. § 1962(c), (d)), civil-rights conspiracy under 42 U.S.C. § 1985(2), and multiple state-law claims; sought injunctive relief including abatement of child support.
The district court dismissed the judges based on absolute judicial immunity, dismissed federal claims on domestic-relations grounds, and declined supplemental jurisdiction over state-law claims; Alexander appealed.
The Sixth Circuit held the domestic relations exception is narrow and did not bar federal jurisdiction here because Alexander sought to vindicate federal rights rather than obtain or modify a divorce/alimony/custody decree.
The court also rejected Rooker–Feldman and Younger abstention as bars to jurisdiction, but affirmed dismissal on the merits: RICO and § 1985 claims failed for insufficient factual allegations; state claims were remanded (supplemental jurisdiction declined).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Domestic-relations exception	Alexander argued federal court could hear conspiracy/civil-rights claims arising from child-support proceedings	Defendants argued the case implicated core family-law matters and belonged in state court	Court: Exception is narrow; does not apply because plaintiff seeks to enforce federal law, not to obtain/modify custody/alimony/divorce
Rooker–Feldman	Alexander claimed injury from defendants' conduct, not the state judgment itself	Defendants argued federal relief would effectively overturn state-court judgment	Court: Rooker–Feldman inapplicable—plaintiff challenges actors' misconduct, not the state judgment
Younger abstention	Alexander sought federal adjudication of constitutional/federal claims	Defendants urged abstention to avoid interference with ongoing state child-support processes	Court: Younger not warranted; federal questions can be resolved without intruding on state proceedings
RICO (18 U.S.C. § 1962)	Alexander alleged mail/wire fraud, bribery, extortion forming a pattern of racketeering	Defendants denied any predicate racketeering acts or enterprise; argued pleadings are conclusory	Court: Dismissed—complaint lacks plausible factual allegations of fraud, extortion, bribery or pattern of racketeering (Iqbal/Twombly standard)
§ 1985(2) conspiracy	Alexander alleged conspiratorial interference with state judicial proceedings, alluding to race/gender bias	Defendants argued no invidious, class-based discriminatory motive alleged	Court: Dismissed—pleading fails to allege required invidious, class-based animus
Judicial immunity & supplemental jurisdiction	N/A (immunity and jurisdictional defenses raised by defendants)	Judges asserted absolute immunity; defendants argued state claims should be retained in state court	Court: Judges entitled to absolute immunity for judicial acts; district court properly declined supplemental jurisdiction over complex/state-law claims

Key Cases Cited

Ankenbrandt v. Richards, 504 U.S. 689 (narrow domestic relations exception to federal jurisdiction)
Catz v. Chalker, 142 F.3d 279 (6th Cir.) (constitutional claims incidental to divorce fall outside domestic-relations exception)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Rooker–Feldman doctrine defined)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards requiring factual plausibility)
Griffin v. Breckenridge, 403 U.S. 88 (class-based animus requirement for conspiracy statute analog)
Stump v. Sparkman, 435 U.S. 349 (judicial immunity for judicial acts)
Forrester v. White, 484 U.S. 219 (limits on immunity for nonjudicial acts)
Middlesex Cty. Ethics Comm. v. Garden State Bar Ass'n, 457 U.S. 423 (Younger abstention principles)