Anthony Allen v. Lawrence DeBello
861 F.3d 433
3rd Cir.2017Background
- Fathers of minor children in New Jersey sued state family-court judges under 42 U.S.C. § 1983 and the Declaratory Judgment Act, challenging New Jersey custody procedures and the "best interests of the child" standard.
- Plaintiffs alleged deprivation of parental rights without adequate notice, counsel, or plenary hearing and claimed bias favoring mothers and indigent parents' lack of counsel.
- Plaintiffs sought declaratory and injunctive relief (e.g., mandatory plenary hearing within ten days when custody is reduced).
- New Jersey law uses a best-interests standard and permits judges discretion to decide some custody motions on affidavits; a plenary hearing is required only when affidavits show a genuine issue of material fact.
- District Court dismissed the judges as improper § 1983 defendants; plaintiffs appealed. The Third Circuit reviewed jurisdictional doctrines (including Rooker‑Feldman) and applied precedent distinguishing judges acting in adjudicative vs. enforcement roles.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker‑Feldman bars the suit | Plaintiffs say they challenge state policies, not state-court judgments | Defendants argued plaintiffs were state-court losers seeking federal review | Rooker‑Feldman did not bar suit because plaintiffs attacked underlying policies/actions, not the judgments themselves |
| Whether state judges are proper § 1983 defendants | Judges enforce unconstitutional custody regime and thus are proper defendants for declaratory/injunctive relief | Judges are neutral adjudicators without power to initiate or administratively enforce the statute | Judges are not proper § 1983 defendants because they acted in an adjudicative (neutral) capacity, not as enforcers or administrators |
| Availability of declaratory relief under the Declaratory Judgment Act (DJA) separate from § 1983 | DJA is coextensive with Article III and could permit declaratory relief naming judges even if § 1983 wouldn’t | District Court applied In re Justices test and declined relief; DJA is discretionary and does not create independent jurisdiction | District Court did not abuse discretion; DJA does not override the proper‑party analysis and is a remedy, not independent jurisdiction |
| Whether abstention/domestic‑relations doctrines bar federal review | Plaintiffs argued federal adjudication was proper | Defendants invoked Younger and domestic relations exceptions | Court found those doctrines did not bar review for reasons relied on below; primary dismissal rested on improper‑party and DJA reasoning |
Key Cases Cited
- Pulliam v. Allen, 466 U.S. 522 (U.S. 1984) (allowed injunctive/declaratory suits against judges before § 1983 amendment)
- Brandon E. ex rel. Listenbee v. Reynolds, 201 F.3d 194 (3d Cir.) (post‑Pulliam § 1983 analysis distinguishing adjudicative vs. enforcement roles)
- Georgevich v. Strauss, 772 F.2d 1078 (3d Cir. 1985) (judges who administer/enforce statutes may be proper § 1983 defendants)
- In re Justices of the Supreme Court of Puerto Rico, 695 F.2d 17 (1st Cir. 1982) (test distinguishing judicial adjudicative vs. nonadjudicative capacity)
- Wilton v. Seven Falls Co., 515 U.S. 277 (U.S. 1995) (DJA confers discretionary remedial jurisdiction)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (clarified Rooker‑Feldman scope)