Prosperous v. Todd, 8:17-cv-01375

Pro se plaintiff Alexandra Prosperous sued four Pinellas County judges (Todd, Coleman, Pierce, Helinger) under 42 U.S.C. § 1983 alleging Fourth and Fourteenth Amendment violations based on rulings and evidentiary decisions in state-family and injunction proceedings.
Allegations included denial of opportunity to present evidence/witnesses, admission of falsified reports, failure to rule on an emergency motion, and threats of arrest for noncooperation.
Plaintiff sought $50,000,000 in punitive damages and asked the court to recommend criminal charges.
Defendants moved to dismiss, arguing lack of subject-matter jurisdiction under Rooker–Feldman, failure to state a claim, Eleventh Amendment immunity, judicial immunity, and qualified immunity.
The Court addressed jurisdiction first, finding Rooker–Feldman only barred claims that sought review of final state-court judgments and noting some state proceedings were pending when this federal suit began and plaintiff primarily sought damages.
The Court nevertheless dismissed the complaint because (1) the pleading failed to plausibly state § 1983 claims and (2) the judicial defendants were entitled to absolute judicial immunity; leave to amend was denied as futile.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Subject-matter jurisdiction under Rooker–Feldman	Challenges to state-court proceedings amount to federal jurisdiction under § 1983	Rooker–Feldman bars federal review of state-court judgments	Rooker–Feldman may bar claims that effectively seek reversal of final state judgments, but does not bar damages claims that do not invite review; some state cases were pending when suit filed, so doctrine did not automatically divest jurisdiction
Failure to state a § 1983 claim	Judicial actions violated Fourth and Fourteenth Amendment rights	Plaintiff’s allegations are vague and do not plead plausible constitutional violations	Complaint fails Rule 8/Iqbal–Twombly plausibility requirements and does not state a plausible § 1983 claim
Judicial immunity	N/A (Plaintiff seeks damages against judges)	Judges are absolutely immune for judicial acts unless in clear absence of jurisdiction	Judges entitled to absolute judicial immunity here because alleged acts were judicial in nature; dismissal warranted
Leave to amend	N/A	Even if allowed, amendment would be futile given immunity and pleading defects	Leave to amend denied as futile; case dismissed and closed

Ashcroft v. Iqbal, 556 U.S. 662 (pleading must state a plausible claim)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for complaints)
Rooker v. Fid. Tr. Co., 263 U.S. 413 (federal courts cannot act as appellate courts over state judgments)
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (Rooker–Feldman doctrine explained)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (limits scope of Rooker–Feldman)
Nicholson v. Shafe, 558 F.3d 1266 (Eleventh Circuit Rooker–Feldman analysis)
Sibley v. Lando, 437 F.3d 1067 (damages claims against judges may avoid Rooker–Feldman)
Douglas v. Yates, 535 F.3d 1316 (affirmation that affirmative defenses like immunity can justify dismissal)