PARRISH v. MILLER
1:25-cv-00429
| S.D. Ind. | Jul 18, 2025Background
- Daniel and Hollie Parrish filed a federal lawsuit related to an ongoing Child in Need of Services (CHINS) proceeding in Indiana state court, naming state agencies and officials as defendants.
- The district court dismissed their initial and first amended complaint for failing to allege sufficient factual bases and because many defendants were immune (sovereign or judicial immunity).
- The Parrishes amended their complaint multiple times to assert claims under 42 U.S.C. § 1983, request injunctive relief, and add Monell claims against the Indiana Department of Child Services (IDCS) and Jennings County.
- The court ruled that the actions sought would interfere with ongoing state court proceedings, requiring abstention under Younger and related doctrines; it found the complaint didn't adequately state a Monell claim.
- The court dismissed the case for lack of subject-matter jurisdiction and denied the Parrishes’ subsequent motion to reconsider under Rule 59(e), finding no manifest error of law, fact, or new evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sovereign and Judicial Immunity | Defendants not immune to claims for damages/injunctive relief in their individual capacities under Ex Parte Young | Many defendants immune due to official capacity, and no bona fide individual-capacity claims stated | Defendants entitled to sovereign/judicial immunity; Parrishes failed to state valid individual-capacity claims |
| Monell Claim Adequacy | Alleged IDCS pattern/practice sufficient to assert Monell liability | Monell claim not plausibly alleged based on facts | Monell claim inadequately pled and dismissed |
| Abstention/Federal Jurisdiction | Relief should be available despite ongoing CHINS case | Federal intervention would interfere with ongoing state case; abstention required | Abstention doctrine applies; federal court must not interfere |
| Rule 59(e) Standard | Court’s dismissal based on legal error/misapprehension; requested reconsideration | No legal/factual error or new evidence shown; just repetition of old arguments | No grounds for reconsideration; motion denied |
Key Cases Cited
- Doe v. Heck, 327 F.3d 492 (7th Cir. 2003) (Eleventh Amendment bars federal suits for damages against state officials in official capacity)
- Brokaw v. Mercer County, 235 F.3d 1000 (7th Cir. 2000) (Federal suits against state officials in official capacity barred by Eleventh Amendment)
- Oto v. Metropolitan Life Ins. Co., 224 F.3d 601 (7th Cir. 2000) (Rule 59(e) reconsideration not for mere dissatisfaction with result)
- Stragapede v. City of Evanston, 865 F.3d 861 (7th Cir. 2017) (Manifest error under Rule 59(e) defined)
- Lightspeed Media Corp. v. Smith, 830 F.3d 500 (7th Cir. 2016) (Rule 59(e) permits amendment only for manifest error or new evidence)
- Moro v. Shell Oil Co., 91 F.3d 872 (7th Cir. 1996) (Reconsideration not for arguments that could have been presented before judgment)