Nue Cheer Franklin v. Arbor Station, LLC, 549 F. App'x 831

Background

Franklin, proceeding pro se and in forma pauperis, sued Arbor Station, its attorney (Parnell), and others in federal court after losing an unlawful detainer action in Alabama state court that resulted in a writ of possession.
Her federal complaint alleged Fourteenth Amendment violations and FDCPA claims based on alleged misrepresentations and fee collection tied to the unlawful detainer proceeding.
Franklin repeatedly amended her complaint; earlier drafts named the state trial and circuit judges, but the district court directed her to omit judicial defendants because of absolute judicial immunity.
The district court dismissed Franklin’s fourth amended complaint without prejudice under 28 U.S.C. § 1915(e)(2)(B)(ii), concluding her claims were barred by res judicata and failed to state a claim; it also declined to consider a proposed fifth amended complaint.
The Eleventh Circuit affirmed, but on the ground that Rooker–Feldman deprived the federal court of subject-matter jurisdiction over Franklin’s federal claims, and therefore over her pendent state-law claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court had subject-matter jurisdiction over federal claims that challenge the state unlawful detainer judgment	Franklin argued her federal due process, equal protection, and FDCPA claims could be heard in federal court without nullifying the state judgments	Defendants argued Rooker–Feldman bars federal review because Franklin’s claims are inextricably intertwined with the state-court judgment	Held: Rooker–Feldman applied; federal courts lacked jurisdiction because prevailing on the federal claims would effectively nullify or overturn the state-court determinations
Whether the district court erred by directing Franklin to omit claims against the state judges	Franklin contended judges acted without jurisdiction (faulty service; improper appellate procedure) so immunity shouldn’t apply	Defendants and court relied on absolute judicial immunity barring damages unless judges acted in clear absence of all jurisdiction	Held: No error; judicial immunity applies and Franklin did not allege the judges acted with knowledge they lacked jurisdiction
Whether the district court properly dismissed state-law claims after finding no federal jurisdiction	Franklin sought adjudication of state-law claims tied to the same underlying events	Defendants argued dismissal of federal claims necessitates dismissal of pendent state claims	Held: Once federal jurisdiction was lacking, state-law claims were correctly dismissed as well
Whether the district court abused discretion by refusing to consider another amendment	Franklin sought leave to add Arbor Station employees, Montgomery County, and courts	Defendants/court argued proposed amendments were futile or barred by Rooker–Feldman and contained only conclusory allegations	Held: No abuse; leave to amend properly denied because proposed amendments were futile and failed to state claims

Key Cases Cited

Casale v. Tillman, 558 F.3d 1258 (11th Cir. 2009) (explaining the Rooker–Feldman doctrine and when claims are inextricably intertwined with state-court judgments)
Scarfo v. Ginsberg, 175 F.3d 957 (11th Cir. 1999) (once federal jurisdiction over federal claims is absent, pendent state-law claims must be dismissed)
Bolin v. Story, 225 F.3d 1234 (11th Cir. 2000) (judicial immunity bars damages for judicial acts unless acted in clear absence of all jurisdiction)
Dykes v. Hosemann, 743 F.2d 1488 (11th Cir. 1984) (judges retain immunity unless they knowingly act without jurisdiction or contrary to clear statutes)
Mizzaro v. Home Depot, Inc., 544 F.3d 1230 (11th Cir. 2008) (district courts may deny leave to amend when amendment is futile)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (conclusory allegations and threadbare recitals are insufficient to state a claim)
Hughes v. Lott, 350 F.3d 1157 (11th Cir. 2003) (standard of review for § 1915(e)(2)(B)(ii) dismissals)