Harbison v. U.S. Senate Committee on Foreign Relations
839 F. Supp. 2d 99
D.D.C.2012Background
- Harbison filed two civil complaints in this court (Nos. 11-cv-1828 and 11-cv-1965) arising from his divorce and related state criminal proceedings.
- The complaints allege broad constitutional, human rights, and war-crimes violations against numerous federal, state, and private defendants.
- The court consolidates the two actions into a single action under 11-cv-1828.
- Defendants include Congressional, federal military, Virginia Commonwealth/County officials and judicial defendants, civil defendants, and Korean defendants.
- The court previously dismissed related habeas petitions and determined the actions rest on the same nucleus of facts as a prior Eastern District of Virginia case; the court will dismiss with prejudice under several theories.
- The court concludes the plaintiff’s claims are frivolous and imposes a filing bar for future actions against these defendants absent court permission against the backdrop of Rule 12(b)(6), res judicata, Rooker-Feldman, judicial immunity, and §1915(e)(2)(B)(i).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Harbison states a plausible claim against all defendants under Rule 12(b)(6). | Harbison contends violations across multiple constitutional and international law theories. | Defendants argue no cognizable legal claim or relief is stated; claims are improperly directed at non-responding defendants and are unsupported. | Yes; the court dismisses for failure to state a claim against all defendants. |
| Whether res judicata bars Harbison’s current claims. | Claims arise from related prior litigation and should be allowed to proceed. | Claims are identical or arise from the same nucleus of facts as the Virginia case. | Yes; barred by res judicata. |
| Whether the Rooker-Feldman doctrine divests the court of jurisdiction. | Discontent with state-court decisions warrants federal review. | Claims seek review of state-court judgments rather than independent federal questions. | Yes; Rooker-Feldman bars relief. |
| Whether judicial Defendants are protected by judicial immunity. | Judicial actions should be scrutinized for misconduct. | Judicial acts are absolutely immune when acting in their judicial capacity. | Yes; judgments against judicial defendants are barred by judicial immunity. |
| Whether the complaint is frivolous under 28 U.S.C. § 1915(e)(2)(B)(i). | Claims constitute legitimate, albeit novel, challenges. | Claims are completely unfounded or fanciful. | Yes; actions dismissed as frivolous with a filing bar. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading must state plausible claims, not mere speculation)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading requires factual content showing plausibility of liability)
- Exxon Mobil Corp. v. Allapattah Servs., 545 U.S. 546 (U.S. 2005) (jurisdictional limits; a district court must assess subject-matter jurisdiction)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (standing requirement; concrete injury needed)
- Stump v. Sparkman, 435 U.S. 349 (U.S. 1978) (judicial immunity for acts within judicial function)
- Rooker v. Fid. Trust Co.; Dist. of Columbia Court of Appeals v. Feldman (Rooker-Feldman Doctrine), 263 U.S. 413; 460 U.S. 462 (U.S. 1923; U.S. 1983) (federal courts cannot review state-court judgments)