Andre Butler v. Doris Pechkurow
669 F. App'x 627
| 3rd Cir. | 2016Background
- Andre D. Butler sued Judge Pechkurow and the City of Philadelphia challenging actions taken in a state family court child support case where Butler was a defendant.
- The district court dismissed Butler’s complaint sua sponte before service under 28 U.S.C. § 1915(e).
- The district court held Judge Pechkurow was protected by judicial immunity and that the court lacked jurisdiction to review the state-court adjudication under Rooker–Feldman.
- The district court also ruled Butler failed to plead any municipal policy or custom sufficient to impose Monell liability on the City.
- Butler appealed; he requested in his brief a declaration that he is not in contempt and an injunction preventing Judge Pechkurow from requiring his appearance in state court.
- The panel affirmed, refusing to grant the requested relief and noting Younger abstention against interfering with ongoing state proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Judicial immunity | Butler challenged judicial acts by Judge Pechkurow in state proceedings | Judge Pechkurow argued her actions were judicial and thus immune from suit | Held: Judicial immunity applies; actions were judicial (Stump) |
| Federal jurisdiction over state-court judgment | Butler sought federal review/relief from state-court orders | Defendants argued Rooker–Feldman bars district-court review of state adjudications | Held: Rooker–Feldman bars such review; district court lacked jurisdiction |
| Municipal liability under § 1983 (Monell) | Butler alleged wrongdoing implicating the City | City argued no policy, custom, or actionable municipal cause pleaded | Held: Complaint failed to allege a policy or custom; Monell claim dismissed |
| Leave to amend | Butler implicitly sought opportunity to amend to cure defects | Defendants argued amendment would be futile given immunity and Monell deficiencies | Held: Leave to amend denied as futile; no plausible amendment could overcome immunity or establish Monell liability |
Key Cases Cited
- Stump v. Sparkman, 435 U.S. 349 (judges immune from civil liability for judicial acts)
- Monell v. Dep’t of Soc. Serv. of City of New York, 436 U.S. 658 (municipal liability under § 1983 requires an official policy or custom)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (federal courts lack jurisdiction to review state-court decisions)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (establishing federal-court jurisdictional bar to review state-court judgments)
- Younger v. Harris, 401 U.S. 37 (federal courts should abstain from interfering with ongoing state proceedings)
- Allah v. Seiverling, 229 F.3d 220 (standard of plenary review for sua sponte dismissals under § 1915(e))
- Phillips v. County of Allegheny, 515 F.3d 224 (general rule favoring leave to amend complaints)
- Grayson v. Mayview State Hosp., 293 F.3d 103 (denying leave to amend when amendment would be futile)