Goodson v. Maggi
2011 U.S. Dist. LEXIS 66962
W.D. Pa.2011Background
- Goodson, pro se, filed §1983/1985/1986/1988 action on behalf of himself and four minor children; minors were dismissed in 2010 and later removed as parties.
- Underlying custody disputes occurred in Pennsylvania and Colorado; Colorado judgment terminated parental rights in 2004 (Judge Walker involved as Colorado magistrate).
- Plaintiff seeks declaratory, injunctive, and monetary relief against numerous defendants, including reversal of Colorado judgment, restoration of parental rights, return of children to Pennsylvania, guardianship by paternal grandparents, remand of custody jurisdiction, and investigation/charges.
- Magistrate Judge Lenihan recommended granting Judge Walker’s Rule 12(b)(6) motion to dismiss; district court adopted the recommendation, noting no objections were filed.
- Court assessed Rooker-Feldman and personal jurisdiction; found equitable-relief claims barred by Rooker-Feldman; monetary claims not barred; no specific/general jurisdiction over Judge Walker; absolute judicial immunity and Eleventh Amendment shield Judge Walker from claims in his official capacity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker-Feldman bars the equitable-relief claims | Father seeks reversal of Colorado custody judgment via federal court | Walker’s actions stem from state-court judgment; relief would overturn state decision | Rooker-Feldman bars equitable-relief claims against Walker |
| Whether federal courts lack subject-matter jurisdiction over relief seeking reversal of a state-court judgment | Claims independent of state judgment; seek federal remedy | Relief depends on state-court judgment; jurisdiction lacking | Equitable-relief claims barred; monetary claims not barred by Exon Mobil/Great Western framework |
| Whether the court has personal jurisdiction over Walker in Pennsylvania | Walker engaged in conspiracy affecting Pennsylvania, justifying jurisdiction | No purposeful contact with Pennsylvania; conspiracy shows insufficient links | No prima facie basis for specific or general jurisdiction over Walker |
| Whether Walker is protected by absolute judicial immunity and Eleventh Amendment | Actions outside immunity; seeks damages and injunctive relief | Rulings in custody cases are judicial acts; immunity applies; Eleventh Amendment bars official-capacity suit | Monetary and injunctive claims against Walker in his individual/official capacity barred by absolute judicial immunity and Eleventh Amendment |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility standard for pleadings; not mere speculation)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (facially plausible claims required; threadbare recitals insufficient)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (narrowly confines Rooker-Feldman to state-court losers seeking review of state judgments)
- Great Western Mining & Mineral Co. v. Fox Rothschild LLP, 615 F.3d 159 (3d Cir. 2010) (four-part test for Rooker-Feldman applicability; source of injury analysis crucial)
- Fowler v. UPMC Shadyside, 578 F.3d 203 (3d Cir. 2009) (two-prong test post-Iqbal for assessing failure to state a claim in civil rights actions)