Charles Evans v. Richard Cordray
424 F. App'x 537
6th Cir.2011Background
- Evans was involved in an Ohio divorce case and faced a vexatious-litigator designation under Ohio Rev. Code § 2323.52, with the state court prohibiting him from filing without leave.
- The domestic-relations court denied Evans leave to proceed in the divorce case on two occasions for failing to obtain leave as required.
- Evans sued in federal court alleging § 2323.52 is unconstitutional as applied to him and others in divorce/domestic relations matters, claiming violations of the First Amendment rights to access to the courts (through the Fifth/Fourteenth Amendments).
- The district court dismissed Evans’s claims under the Rooker-Feldman doctrine, concluding the suit impermissibly challenged state-court judgments.
- Evans appealed, arguing (a) he asserts both a § 1983 substantive-rights claim and a general challenge to the statute as applied; (b) his claims attack the statute’s procedure, not the state court’s judgments.
- The Sixth Circuit reversed, holding the source of Evans’s injury is the alleged unconstitutionality of § 2323.52 as applied in divorce proceedings, not the state-court denial of leave, so Rooker-Feldman does not bar the suit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Rooker-Feldman bar Evans's federal claims? | Evans: injury from unconstitutional statute, not state judgments. | Cordray/Ohio: claims attack state-court denial of leave. | No; Rooker-Feldman does not bar the suit because injury arises from statute’s application, not state judgments. |
| Is Evans's suit an improper appeal of the vexatious-litigator decision? | Evans seeks broad constitutional relief, not to overturn the vexatious-litigator ruling. | District court treated as improper federal appeal of state ruling. | No; Evans challenges the constitutionality of the statute as applied, not the state-court finding. |
| Is Evans entitled to prospective, ongoing relief against enforcement of § 2323.52? | Evans seeks injunctive and declaratory relief against future enforcement. | Rooker-Feldman precludes review of state judgments; no independent claim. | Yes; the source of injury is ongoing enforcement, not past state judgments, so federal jurisdiction exists. |
Key Cases Cited
- Carter v. Burns, 524 F.3d 796 (6th Cir. 2008) (limits of Rooker-Feldman; not barred when challenge is to constitutionality of state law as applied)
- McCormick v. Braverman, 451 F.3d 382 (6th Cir. 2006) (source of injury governs whether RF applies)
- Hood v. Keller, 341 F.3d 593 (6th Cir. 2003) (RF not applicable where plaintiff seeks prospective relief from unconstitutional rule as applied)
- Buckley v. Illinois Judicial Inquiry Board, 997 F.2d 224 (7th Cir. 1993) (distinguishes challenges to rule from challenges to disciplinary judgment)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (RF limits on review of state-court judgments; depends on the nature of the claim)
- Fieger v. Ferry, 471 F.3d 637 (6th Cir. 2006) (RF not to bar claims challenging contemporaneous constitutional issues apart from past judgments)