764 F. App'x 53
2d Cir.2019Background
- Pro se plaintiff Chris Henry sued New York State, New York City, a police officer, a state supreme court justice (Justice Dawson), and two Family Court support magistrates (Ryneski and Clarke) over actions in his divorce/support proceedings and an arrest for violating an order of protection.
- Henry's operative complaint contained 39 counts asserting federal civil-rights claims (e.g., § 1983/§ 1985) and state-law tort claims arising from the state-court matrimonial and support proceedings and related enforcement.
- The district court dismissed the federal claims (including as time-barred, barred by sovereign immunity, judicial/quasi-judicial immunity, or Rooker–Feldman) and declined supplemental jurisdiction over state claims; Henry appealed.
- Henry did not contest on appeal certain dismissals (claims against Officer Rios as time‑barred and against the Commissioner), and he failed to adequately plead any municipal policy causing the alleged constitutional violations.
- The Second Circuit affirmed: Eleventh Amendment barred official-capacity claims against the State and judicial defendants; judicial/quasi‑judicial immunity barred individual‑capacity claims; Rooker–Feldman barred challenges that effectively sought review of state-court judgments; the court declined to exercise supplemental jurisdiction over state claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Eleventh Amendment permits Henry’s damages claims against the State and judicial defendants in official capacity | Henry sought damages against the State and judicial officers for actions in state proceedings | State/defendants argued sovereign immunity bars such federal damages suits | Eleventh Amendment bars damages suits against the State and state officers in official capacity (affirmed) |
| Whether judicial/quasi‑judicial immunity bars money‑damages claims against Justice Dawson and support magistrates in their individual capacities | Henry alleged judicial misconduct (e.g., wrongful order of protection, property rulings, falsified evidence) | Defendants argued their actions were judicial/quasi‑judicial and within subject‑matter jurisdiction, so absolute immunity applies | Judicial and quasi‑judicial immunity applies; individual‑capacity claims dismissed |
| Whether Rooker–Feldman permits federal review of challenges to state‑court judgments (fraud-in‑procurement/falsified evidence claims) | Henry argued state judgments were procured by fraud and sought federal relief overturning them | Defendants invoked Rooker–Feldman and claim‑preclusion—federal courts lack jurisdiction to review state‑court judgments | Rooker–Feldman (and res judicata principles) bars federal review of claims inextricably intertwined with state judgments |
| Whether district court erred in dismissing remaining state‑law claims after federal claims were dismissed | Henry wanted his state tort claims heard in federal court | Defendants argued court should dismiss state claims once federal claims dismissed | Court properly declined supplemental jurisdiction under 28 U.S.C. § 1367(c)(3); state claims dismissed without abuse of discretion |
Key Cases Cited
- Will v. Michigan Dep’t of State Police, 491 U.S. 58 (official‑capacity suits are suits against the State and barred by Eleventh Amendment)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (federal courts lack jurisdiction to review state court decisions)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (only the Supreme Court may review state court judgments)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (elements of Rooker–Feldman jurisdictional bar)
- Huminski v. Corsones, 396 F.3d 53 (test for judicial immunity: judicial nature and subject‑matter jurisdiction)
- Butz v. Economou, 438 U.S. 478 (quasi‑judicial immunity for nonjudicial officials performing judge‑like functions)
- Carnegie‑Mellon Univ. v. Cohill, 484 U.S. 343 (declining supplemental jurisdiction over state claims after federal claims are dismissed)