MATHIS v. MATHIS, 2:14-cv-05089

Derrick Mathis (plaintiff) sued ex-wife Francine Mathis and her attorney for actions during state divorce/custody proceedings, seeking money damages and restoration of custody/visitation rights.
Plaintiff alleges defendants made misrepresentations to the state court (including false abuse allegations), procured a protection-from-abuse order, and used the court to create child-support arrears.
Plaintiff asserted violations of "human rights," civil rights, assault, and defamation; he sought to proceed in forma pauperis.
The district court screened the complaint under 28 U.S.C. § 1915(e)(2)(B)(ii) and Rule 12(b)(6) standards, construing pro se allegations liberally.
Court determined federal jurisdiction was unavailable: Rooker-Feldman barred review of adverse state-court judgments, and § 1983 claims failed because defendants were not state actors.
Diversity jurisdiction was lacking (all parties appear to be Pennsylvania citizens); court dismissed the complaint without prejudice and denied leave to amend.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court may review and overturn state-court custody/visitation decisions	Mathis asks federal court to remedy custody/visitation harms caused by defendants' alleged misconduct	Defendants implicitly argue state-court judgments control; federal court lacks authority	Dismissed under Rooker-Feldman — federal court cannot review/reject state-court judgments
Whether defendants are state actors for § 1983 liability	Mathis contends defendants' lies/actions to procure orders violated his civil rights	Defendants are private actors (ex-wife and private counsel) and did not act under color of state law	§ 1983 claim fails — no plausible allegation of state action or conspiracy with judge
Whether court has subject-matter jurisdiction over state-law claims	Mathis seeks to pursue state-law torts in federal court	Defendants contend (implicitly) that federal jurisdiction is lacking; diversity absent	No diversity jurisdiction (all parties Pennsylvania citizens); state-law claims must be brought in state court
Whether plaintiff may amend to cure defects	Mathis could replead to add facts	Defects involve jurisdictional and fundamental failures to state federal claims	Leave to amend denied — defects not curable; dismissal without prejudice to state-court refiling

Tourscher v. McCullough, 184 F.3d 236 (3d Cir.) (§ 1915 screening uses Rule 12(b)(6) standard)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleadings)
Higgs v. Attorney General, 655 F.3d 333 (3d Cir.) (liberal construction of pro se pleadings)
Great W. Mining & Mineral Co. v. Fox Rothschild, LLP, 615 F.3d 159 (3d Cir.) (Rooker-Feldman doctrine limits federal review of state-court judgments)
Groman v. Township of Manalapan, 47 F.3d 628 (3d Cir.) (elements of § 1983 require state action)
Angelico v. Lehigh Valley Hospital, Inc., 184 F.3d 268 (3d Cir.) (private attorneys performing traditional functions are not state actors)
Dennis v. Sparks, 449 U.S. 24 (1980) (private party winning in court does not become a co-conspirator with judge absent clear joint action)
Harvey v. Plains Township Police Department, 421 F.3d 185 (3d Cir.) (joint action requirement for § 1983 conspiracies)
Grayson v. Mayview State Hospital, 293 F.3d 103 (3d Cir.) (denial of leave to amend where defects cannot be cured)