Melton v. District of Columbia, 85 F. Supp. 3d 183

Background

In Feb 2012 Shaquita Robinson gave birth to J.R.; both tested positive for cocaine. Robinson abandoned J.R.; CFSA took custody and commenced neglect proceedings in D.C. Family Court. Plaintiff (father) was incarcerated in Virginia throughout the relevant period and later confirmed by paternity testing.
Plaintiff was served and had counsel (David Stein) appointed; he sought reunification and proposed kin placement with his niece, Zanielle Young. CFSA placed J.R. with Young and later pursued permanent adoption; Family Court adjudicated J.R. neglected after Robinson stipulated.
Plaintiff alleges he was denied meaningful participation in case planning, denied reunification services because of incarceration, and that CFSA and Stein conspired to change J.R.’s permanency goal to adoption and to terminate his parental rights.
Plaintiff sued under 42 U.S.C. §§ 1983 and 1985 and asserted claims under the Adoption Assistance and Child Welfare Act seeking injunctive relief and damages; CFSA, District defendants, and Stein moved to dismiss.
The district court found it lacked no subject-matter jurisdiction (denying Rooker-Feldman and domestic-relations dismissal), but dismissed the complaint on the merits under Rule 12(b)(6): CFSA is non sui juris; Adoption Assistance Act supplies no private right; § 1983 and § 1985 claims were inadequately pleaded; and individual CFSA actors enjoyed absolute or qualified immunity.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Subject-matter jurisdiction / Rooker‑Feldman & domestic-relations	Claims arise from defendants' extrajudicial actions, not a request to overturn Family Court; federal court may hear constitutional claims	Family Court and D.C. courts have primary jurisdiction; Rooker‑Feldman and domestic‑relations doctrines bar federal review of family judgments	Denied defendants' jurisdictional dismissal; Rooker‑Feldman not invoked because plaintiff did not seek review of an existing Family Court judgment and domestic‑relations exception inapplicable here
Claim under Adoption Assistance and Child Welfare Act	Defendants failed to make reasonable efforts and denied statutory services to father	The Act creates federal funding conditions, not a private cause of action enforceable by individuals	Dismissed: Suter and controlling precedent hold the Act does not confer an enforceable private right or § 1983 remedy
§ 1983 – municipal liability and customs/policies	CFSA/District policies and supervisors discriminated by denying services to incarcerated father	Complaint fails to identify any municipal policy or custom causing constitutional violation; respondeat superior unavailable	Dismissed: pleadings lack factual allegations identifying a District policy or practice sufficient for Monell liability
§ 1983 – Stein as a state actor	Stein conspired with CFSA and acted under color of law to deprive father of rights	Court‑appointed counsel performing traditional functions are not state actors for § 1983	Dismissed as to Stein: no allegation of conspiracy with state actors that would convert him into a state actor
§ 1985 conspiracy claim	CFSA and others conspired to deprive equal protection and parental rights	Complaint contains only conclusory conspiracy assertions and fails to allege class‑based discriminatory animus	Dismissed: plaintiff failed to plead agreement plus class‑based invidious animus required under § 1985(3)
CFSA and individual immunities	CFSA staff acted improperly in Court filings and case planning	CFSA is non sui juris; individual caseworkers and prosecuting attorney functions are entitled to absolute/qualified immunity for court‑related acts	CFSA dismissed as a party; individual CFSA defendants protected by absolute immunity for courtroom testimony/advocacy and qualified immunity for investigatory/discretionary acts

Key Cases Cited

Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (federal courts are courts of limited jurisdiction) (quoted for jurisdictional principles)
Jerome Stevens Pharm., Inc. v. Food & Drug Admin., 402 F.3d 1249 (D.C. Cir.) (courts may consider materials outside the pleadings on Rule 12(b)(1))
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Rooker‑Feldman doctrine scope)
District of Columbia v. Feldman, 460 U.S. 462 (Rooker‑Feldman and limits on federal review of state court judicial decisions)
Suter v. Artist M., 503 U.S. 347 (Adoption Assistance and Child Welfare Act does not create private right enforceable via § 1983)
Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658 (municipal liability under § 1983 requires an official policy or custom)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard: ‘‘plausibility’’ for § 1983 and other constitutional claims)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standards and dismissal for failure to state a claim)
Stanley v. Illinois, 405 U.S. 645 (parental liberty interest in custody and care of children)
Santosky v. Kramer, 455 U.S. 745 (due process protections required for termination of parental rights)
Imbler v. Pachtman, 424 U.S. 409 (absolute immunity for certain prosecutorial/judicial functions)
Rehberg v. Paulk, 566 U.S. 356 (absolute immunity for witness testimony in judicial proceedings)
Gray v. Poole, 275 F.3d 1113 (D.C. Cir.) (distinguishing absolute vs qualified immunity for child‑welfare actors)