Campbell v. City of Spencer
2012 U.S. App. LEXIS 12848
| 10th Cir. | 2012Background
- Dr. Campbell owned horses on property in Spencer (City) and Forest Park (Town), Oklahoma.
- Authorities seized 44 horses following an animal-welfare investigation and obtained state-forfeiture orders tied to a bond for maintenance costs.
- The City and Town sought forfeiture and a maintenance bond under Okla. Stat. tit. 21, § 1680.4(C)(1).
- After state court proceeding, Campbell challenged the forfeiture and bond determinations; relief was denied in state court and by the Oklahoma Supreme Court.
- Campbell filed a 42 U.S.C. § 1983 action in federal court alleging Fourth, Fifth, and Eighth Amendment violations; the district court dismissed under Rooker-Feldman.
- The district court dismissed Fourth Amendment claims as intertwined with the state judgment; Fourth Amendment claims are not barred whereas Fifth and Eighth Amendment claims are barred by Rooker-Feldman.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker-Feldman bars the Fifth Amendment claim | Fifth claim challenges preforfeiture actions, not the state judgment. | Fifth claim seeks relief tied to the state-forfeiture judgment. | Barred by Rooker-Feldman. |
| Whether Rooker-Feldman bars the Eighth Amendment claim | Eighth claim alleges excessive fines from bond/forfeiture. | Injury stems from the state judgment. | Barred by Rooker-Feldman. |
| Whether Fourth Amendment claims survive despite state-forfeiture judgment | Search and seizure occurred before the state judgment; federal review is available. | Claims are dependent on the state judgment’s legality. | Not barred; Fourth Amendment claims proceed. |
Key Cases Cited
- Rooker v. Fid. Trust Co., 263 U.S. 413 (Supreme Court 1923) (limits federal appellate review of state-court judgments)
- Feldman v. City of Washington, 460 U.S. 462 (Supreme Court 1983) (limits federal review of state-initiated judicial decisions)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Supreme Court 2005) (redefines Rooker-Feldman to exclude preclusion concerns; focus on injuries from state judgment)
- Bolden v. City of Topeka, 441 F.3d 1129 (10th Cir. 2006) (Rooker-Feldman not to bar claims not seeking appellate review of a state judgment)
- Kenmen Eng’g v. City of Union, 314 F.3d 468 (10th Cir. 2002) (illustrates injury from state-court order and the limits of Rooker-Feldman)