Contreras v. Perimenis, 562 F. App'x 50

Contreras appeals a district court judgment dismissing her amended complaint against Perimenis, Edgar, Castro, White, and Flash.
The district court dismissed for failure to state a claim under Rule 12(b)(1) and 28 U.S.C. § 1915(e)(2), with liberal construction of pro se pleadings.
Contreras sought relief including reversal of a state child neglect finding; the court noted lack of jurisdiction to review such state judgments under Feldman and Rooker‑Feldman.
The court held Hensley Flash had absolute immunity as a government attorney prosecuting child welfare cases.
The district court also denied leave to amend; the Second Circuit conducted an independent de novo review and affirmed.
The panel acknowledged pro se status but affirmed dismissal for lack of plausibility and immunity defenses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the amended complaint plausibly states a claim against any defendant	Contreras argues discrimination and liability based on national origin	District court found claims implausible under Twombly/Iqbal	Dismissal upheld
Whether the state court’s child neglect finding is reviewable by the federal courts	Contreras seeks reversal of the state court judgment	Rooker‑Feldman divests federal review of such state-court judgments	Lacked jurisdiction to review the state judgment
Whether Hensley Flash has absolute immunity from § 1983 liability	Contreras sues the attorney personally	Attorney prosecuted child welfare cases in official capacity	Affirmative absolute immunity for government advocates
Whether the district court properly denied leave to amend	Amendment would correct pleading defects	amendment would be futile	No abuse of discretion; denial affirmed

Triestman v. Fed. Bureau of Prisons, 470 F.3d 471 (2d Cir. 2006) (pro se pleadings receive liberal construction; strong claims considered)
Cuoco v. Moritsugu, 222 F.3d 99 (2d Cir. 2000) (leave to amend typically required at least once)
Pangburn v. Culbertson, 200 F.3d 65 (2d Cir. 1999) (leave to amend may be denied if futile)
Walden v. Wishengrad, 745 F.2d 149 (2d Cir. 1984) (immunity for government attorneys prosecuting cases)
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983) (federal courts lack jurisdiction to review final state-court judgments)
Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) (federal jurisdiction barred to review state court decisions)
Jaghory v. New York State Dep’t of Educ., 131 F.3d 326 (2d Cir. 1997) (de novo review of dismissal standards; pleading sufficiency standards)
Giano v. Goord, 250 F.3d 146 (2d Cir. 2001) (pleading standards and plausibility in § 1983 actions)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleading; legal conclusions require factual support)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for surviving dismissal)