Martin Parness v. Christopher Christie, 18-1107

Parness, previously held in civil contempt and jailed in New Jersey after a 2003 state-family-court judgment, sued numerous state and federal actors in federal court alleging RICO and §1983 conspiracies tied to his post-2009 incarceration and collection of the state-court judgment.
His initial pro se complaint (filed 2015) was dismissed under 28 U.S.C. §1915(e)(2)(B) as time‑barred in part and for lack of subject‑matter jurisdiction under Rooker‑Feldman for claims that would impermissibly attack state-court judgments; he did not appeal that dismissal.
Parness filed a substantially similar amended complaint in 2017; the District Court treated it as an amendment to the earlier case, reopened the original docket, and again dismissed under §1915(e)(2)(B) for being time‑barred, failing to state a claim, or being barred by Rooker‑Feldman.
The District Court applied Rule 12(b)(6)/Twombly pleading standards and state statutes of limitations (New Jersey two‑year rule for §1983‑type claims) in rejecting several claims.
On appeal the Third Circuit affirmed, agreeing the complaint was time‑barred as to the first RICO conspiracy, some §1983 claims were untimely or deficient, supplemental jurisdiction could be declined for state‑law claims, and that the remaining federal claims were barred by Rooker‑Feldman.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of first RICO claim	Parness argued accrual occurred later (July 2011) so claim was timely	Defendants: claim accrued by 2009–2010 when Parness knew of injury and parties; thus barred by 4‑year RICO statute	Held: accrual by Aug 2010 at latest; RICO claim time‑barred
Applicability of Rooker‑Feldman (jurisdiction)	Parness argued later Third Circuit authority limited Rooker‑Feldman and he raised independent federal claims	Defendants: federal court lacks jurisdiction because success would void/state‑court judgments	Held: Rooker‑Feldman applies — claims attack state judgments; federal court lacks jurisdiction
§1983 claims statute of limitations / sufficiency	Parness pressed due process and conspiracy claims tied to state proceedings	Defendants: §1983 claims governed by NJ two‑year statute; many claims untimely or fail to plead facts	Held: many §1983 claims untimely or fail to state a claim; dismissed
District Court dismissal under §1915(e)(2)(B)	Parness contended dismissal was improper and cited intervening authority	Defendants: dismissal proper for frivolous/untimely/insufficient claims	Held: District Court properly dismissed under §1915(e)(2)(B) and Rule 12(b)(6)

Mathews v. Kidder, Peabody & Co., 260 F.3d 239 (3d Cir. 2001) (RICO statute of limitations accrual analysis)
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (federal courts cannot review final state‑court judgments)
Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) (federal courts lack jurisdiction to review state‑court decisions)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility pleading standard)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (framework for Rooker‑Feldman scope)
Taliaferro v. Darby Twp. Zoning Bd., 458 F.3d 181 (3d Cir. 2006) (application of Rooker‑Feldman in Third Circuit)
Great W. Mining & Mineral Co. v. Fox Rothschild LLP, 615 F.3d 159 (3d Cir. 2010) (limits on “inextricably intertwined” test; use Exxon factors)
In re Philadelphia Ent. & Dev. Partners, 879 F.3d 492 (3d Cir. 2018) (federal jurisdiction where independent claim exists despite related state rulings)
Kost v. Kozakiewicz, 1 F.3d 176 (3d Cir. 1993) (12(b)(6) tests sufficiency of factual allegations)
Fowler v. UPMC Shadyside, 578 F.3d 203 (3d Cir. 2009) (distinguishing factual allegations from legal conclusions)
Cito v. Bridgewater Twp. Police Dep’t, 892 F.2d 23 (3d Cir. 1989) (use of state personal‑injury statute of limitations for §1983 claims)
Ahmed v. Dragovich, 297 F.3d 201 (3d Cir. 2002) (post‑judgment reopening governed by Rules 59 and 60)