Bloom v. State of Washington
2:24-cv-02155
W.D. Wash.May 5, 2025Background
- Gina Bloom sued various state and local entities and officials, alleging constitutional violations arising out of family court proceedings related to her divorce and custody dispute in Snohomish County, Washington.
- Plaintiff lost custody of her children amid allegations of domestic violence, with decisions made by court commissioners, judges, and a court-appointed Guardian Ad Litem (GAL).
- After unfavorable rulings at the trial level and on appeal, Bloom brought federal claims under 42 U.S.C. § 1983 and asserted violations of the First, Fourth, Fifth, and Fourteenth Amendments.
- Defendants moved to dismiss, raising federal jurisdictional barriers, judicial and Eleventh Amendment immunity, and pleading deficiencies.
- The court addressed whether it had subject matter jurisdiction under the Rooker-Feldman doctrine, addressed judicial and governmental immunities, and examined the sufficiency of the Monell claim against the County concerning oversight of GALs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Rooker-Feldman Doctrine: Jurisdiction | Claims do not seek to undo state court judgments, but challenge judicial misconduct & constitutional violations. | Plaintiff's suit is a de facto appeal of state court decisions; all relief sought relates to state court outcomes. | Claims barred; court lacks jurisdiction over most claims. |
| Judicial Immunity | Judges acted in administrative/excess of jurisdiction roles, so not immune. | All challenged actions are judicial in nature, protected by absolute immunity. | Judicial defendants immune; dismissed with prejudice. |
| Eleventh Amendment/§ 1983: State Liability | State should be liable for failing to correct GAL program issues; may amend to add officials. | State not a “person” under §1983; Eleventh Amendment bars suit; no basis to amend. | State dismissed with prejudice; no leave to amend. |
| Monell Claim vs. County (GAL oversight) | County had customs/policies of failing to supervise/train GALs, enabling constitutional violations. | Plaintiff's allegations are conclusory; insufficient factual support for a policy/custom causing the alleged harm. | Dismissed without prejudice; leave to replead given. |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Rooker-Feldman doctrine bars federal review of state-court judgments)
- Noel v. Hall, 341 F.3d 1148 (Ninth Circuit test for Rooker-Feldman application)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausibility in federal court)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (complaint must provide more than conclusory statements)
- Mireles v. Waco, 502 U.S. 9 (judicial immunity protects judges for judicial acts)
- Will v. Michigan Dep’t of State Police, 491 U.S. 58 (states are not “persons” under § 1983)
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipal liability under § 1983 requires a policy or custom)