Glass v. U.S. Department of Health & Human Services
Civil Action No. 2017-0428
| D.D.C. | Nov 14, 2017Background
- Plaintiff Thomas Glass challenged Florida child-support enforcement and agency processing after administrative review reduced a support recommendation but the state did not file a proposed modified order; he alleged he nonetheless remained obligated to pay higher amounts and twice paid in one month due to employer assignment errors.
- Glass filed an amended complaint in D.C. Superior Court naming the U.S. Department of Health & Human Services (DHHS), the Florida Department of Revenue, and the Miami‑Dade State Attorney’s Office; DHHS removed the case to federal court.
- Claims invoked federal child‑support regulations implementing Title IV‑D and sought reimbursement for alleged overpayments, correction of income‑deduction orders, and damages for tort/abuse of process; plaintiff sought to add a state hearing officer as a defendant in a proposed second amended complaint.
- The State Defendants moved to dismiss on Eleventh Amendment grounds and argued sovereign‑immunity and Rooker‑Feldman limitations; DHHS moved to dismiss for failure to state a claim and for lack of service (the court denied the service challenge as moot).
- The district court denied leave to amend (futile) and granted defendants’ motions to dismiss, holding state agencies immune under the Eleventh Amendment, the United States immune absent waiver, Rooker‑Feldman barred federal review of state‑court orders, and Title IV‑D does not confer an individual private right to enforce state compliance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Leave to amend to add hearing officer Valerie Tomkins | Tomkins committed official misconduct by dismissing or failing to continue his modification motion; seeks money and correction of orders | Tomkins is a judicial actor entitled to absolute judicial immunity; amendment would be futile and barred by Rooker‑Feldman if intended to alter state court orders | Denied: amendment futile—judicial immunity protects Tomkins and Rooker‑Feldman bars federal collateral attack |
| Eleventh Amendment immunity of Florida agencies | Glass seeks damages and relief against Florida Dept. of Revenue and State Attorney’s Office | Florida agencies are arms of the state and immune unless waiver shown | Dismissed for lack of subject‑matter jurisdiction due to Eleventh Amendment immunity |
| Sovereign immunity of United States/DHHS | DHHS named in caption; plaintiff alleges regulatory violations | United States has not waived sovereign immunity for these claims | Dismissed for lack of subject‑matter jurisdiction due to sovereign immunity |
| Failure to state a claim / federal remedy for Title IV‑D violations | Regulations (45 C.F.R.) and audits were violated; seeks enforcement, reimbursement and correction of income deduction orders | No private right to force state Title IV‑D compliance; Rooker‑Feldman prevents federal review of state court support orders; complaint lacks plausible factual allegations against DHHS | Dismissed for failure to state a claim: no private right under Title IV‑D and Rooker‑Feldman bars requested relief |
Key Cases Cited
- Stump v. Sparkman, 435 U.S. 349 (state judges are immune from damage suits for acts within their judicial capacity)
- Butz v. Economou, 438 U.S. 478 (administrative hearing officers may be entitled to judicial immunity)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (describing scope of Rooker‑Feldman doctrine)
- District of Columbia v. Feldman, 460 U.S. 462 (federal district courts lack jurisdiction to review final state court judicial decisions)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (establishing principle precluding federal collateral review of state court judgments)
- College Sav. Bank v. Florida Prepaid Postsecondary Educ. Expense Bd., 527 U.S. 666 (Eleventh Amendment bars suits against states absent consent)
- FDIC v. Meyer, 510 U.S. 471 (United States sovereign immunity principles and limitations on suits against the federal government)
- Blessing v. Freestone, 520 U.S. 329 (no individual private right to compel state Title IV‑D compliance)