Kehoe v. Walker
2:25-cv-01146
| D. Nev. | Jun 30, 2025Background
- Plaintiff Nelin Kehoe filed suit in the U.S. District Court for the District of Nevada against multiple defendants, all located in New York (Tamra Walker, Queens Family Court, New York State Unified Court System, Ahu Kip).
- Plaintiff also applied to proceed in forma pauperis (without paying court fees), which the court granted.
- The alleged underlying events all occurred in New York, specifically involving proceedings in the Queens Family Court.
- Plaintiff's complaint sought relief against these New York-based defendants for actions connected with New York family court proceedings.
- The court screened the complaint under 28 U.S.C. § 1915(e)(2), which allows early dismissal of cases lacking legal basis, and found jurisdictional issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Nevada court has personal jurisdiction over NY-based defendants | Not clearly specified; seeks to sue NY individuals/entities in Nevada | No Nevada contacts or actions alleged; all parties/events in NY | No Nevada jurisdiction; dismissal without prejudice |
| Immunity of state court entities | Not addressed | NY courts immune from suit | Queens Family Court and NY Unified Court System are immune |
| Sufficiency of factual pleadings | Complaint alleges harm from NY proceedings | Defendants (implicitly) argue no actionable Nevada connection | Complaint lacks facts for Nevada venue/jurisdiction |
| Leave to amend in Nevada | Should be given opportunity | N/A | Dismissal without leave to amend in Nevada; may refile in NY |
Key Cases Cited
- Neitzke v. Williams, 490 U.S. 319 (screening standard for dismissing frivolous or baseless in forma pauperis complaints)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards under Rule 12(b)(6))
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (standards for stating a claim)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (requirements for specific personal jurisdiction)
- Ford Motor Co. v. Montana Eighth Jud. Dist. Ct., 592 U.S. 351 (scope of minimum contacts for personal jurisdiction)
- Warshaw v. Xoma Corp., 74 F.3d 955 (reviewing standard for well-pleaded facts in dismissal)