Brigham v. Ramirez
8:10-cv-01327
M.D. Fla.Oct 27, 2010Background
- Plaintiffs Dana and Patricia Brigham sue under 42 U.S.C. § 1983 for due process violations arising from a state-court proceeding.
- The Third District Court of Appeal reversed and remanded with instructions to enter judgment for appellants; it remanded for further proceedings consistent with its opinion.
- The Brighams sought rehearing, rehearing en banc, and Florida Supreme Court review, all of which were denied.
- After remand, only issues purely involving state law remained: attorneys’ fees and costs, punitive damages, and removal of Dana Brigham as trustee.
- The federal action challenges the state court’s due process decisions as “inextricably intertwined” with the state judgment and seeks to overturn the state appellate ruling.
- The magistrate recommended dismissal under the Rooker-Feldman doctrine; the district court granted dismissal accordingly.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker-Feldman bars the federal action | Brighams argue state proceedings not ended | State judgments finalized; issues reviewed | Barred; lack of jurisdiction under Rooker-Feldman |
| Whether Brighams had a reasonable opportunity to raise federal claims in state court | There was no reasonable opportunity | Federal issues could have been raised in state court | Yes; preventive opportunity existed; claims are barred as要 intertwined with state judgment |
| Whether the federal claims are inextricably intertwined with the state court decision | Claims directly challenge state court ruling | Claims are intertwined and seek reversal of state decision | Inextricably intertwined; Rooker-Feldman applies |
| Whether the action is a de facto appeal of state court proceedings | Action seeks federal review of state-court errors | Action is a de facto appeal; improper in federal court | De facto appeal; barred under Rooker-Feldman |
Key Cases Cited
- Federacion de Maestros de Puerto Rico v. Junta de Relaciones del Trabajo de Puerto Rico, 410 F.3d 17 (1st Cir. 2005) (defines when state proceedings are ended for Rooker-Feldman purposes)
- Casale v. Tillman, 558 F.3d 1258 (11th Cir. 2009) (claims inextricably intertwined with state court judgment)
- Nicholson v. Shafe, 558 F.3d 1266 (11th Cir. 2009) (states when state proceedings have ended for Rooker-Feldman purposes)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Supreme Court 2005) (establishes the Rooker-Feldman doctrine scope)