Horst v. Keller, 1:19-cv-00081

Pro se plaintiff Charlotte Horst filed a voluminous complaint (39 pages) with ~360 pages of attachments against ~113 defendants, challenging state-court domestic-relations orders, criminal proceedings, probation revocation, license suspension, and alleged police/prosecutorial misconduct.
She sought to proceed in forma pauperis and requested preliminary injunctive relief; the magistrate granted pauper status and screened the complaint under 28 U.S.C. § 1915(e)(2).
Horst alleged numerous constitutional and statutory violations (First through Twenty-First Amendments, Title VII, VAWA, Title IX, international treaties), and advanced factual and legal theories including kidnapping of her children by schools, fabrication/destruction of evidence, and various conspiracy theories tied to state actors.
The magistrate found the pleading failed to comply with Fed. R. Civ. P. 8 due to shotgun-style allegations that do not give defendants fair notice of claims against them.
The magistrate concluded many claims are frivolous or incomprehensible, that Horst lacks standing for private enforcement of criminal/ethical rules, and that many defendants (judges, prosecutors) enjoy absolute immunity.
The magistrate further held federal subject-matter jurisdiction is lacking under the Rooker–Feldman doctrine and the domestic-relations exception and recommended dismissal without prejudice under § 1915(e)(2).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Horst may proceed without prepaying fees	Horst asserted indigence and sought IFP status	Defendants did not contest pauper status	Court granted IFP (28 U.S.C. § 1915(a))
Whether the complaint satisfies Rule 8	Horst presented lengthy multi-defendant allegations; sought broad relief	Defendants implicitly argued pleading is deficient	Court: complaint violates Rule 8; shotgun pleading fails to provide fair notice
Whether claims are frivolous or fail to state a claim	Horst alleged numerous constitutional and statutory violations and factual conspiracies	Defendants rely on law limiting merit and plausibility of such claims	Court: many claims frivolous or implausible; subject to dismissal under § 1915(e)(2)
Whether judicial/prosecutorial defendants are amenable to suit	Horst alleges misconduct by judges/prosecutors and related officials	Defendants assert absolute judicial and prosecutorial immunity	Court: judges/prosecutors (and related officials acting pursuant to judicial orders) have absolute immunity; many claims barred
Whether federal court has jurisdiction over Horst's domestic-relations and state-judgment challenges	Horst seeks review/relief tied to state divorce, custody, support, and state-court rulings	Defendants rely on Rooker–Feldman and domestic-relations exception to bar federal review	Court: Rooker–Feldman and domestic-relations doctrines deprive federal court of jurisdiction; dismissal recommended

Neitzke v. Williams, 490 U.S. 319 (1989) (defines frivolousness standard under § 1915)
Denton v. Hernandez, 504 U.S. 25 (1992) (frivolousness and no arguable basis in law or fact)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (application of Twombly plausibility standard to civil complaints)
Imbler v. Pachtman, 424 U.S. 409 (1976) (prosecutorial absolute immunity)
Mireles v. Waco, 502 U.S. 9 (1991) (judicial immunity principles)
Stump v. Sparkman, 435 U.S. 349 (1978) (judge immune for judicial acts even if erroneous or malicious)
Buckley v. Fitzsimmons, 509 U.S. 259 (1993) (scope of absolute immunity for prosecutorial functions)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (Rooker–Feldman doctrine scope)
Keene Corp. v. Cass, 908 F.2d 293 (8th Cir. 1990) (federal courts lack appellate jurisdiction over state-court proceedings)
Linda R.S. v. Richard D., 410 U.S. 614 (1973) (private citizen lacks judicially cognizable interest in prosecution of another)