(PS) Todd v. Drozd
2:13-cv-02071
E.D. Cal.Oct 10, 2013Background
- Todd, proceeding pro se, sought in forma pauperis status in an action filed in the Eastern District of California.
- The court granted in forma pauperis status under 28 U.S.C. § 1915(a).
- The complaint challenges state custody orders and related domestic relations orders.
- The court discusses the standard for frivolity and failure to state a claim under 28 U.S.C. § 1915(e)(2) and Twombly/Iqbal.
- The court concludes it lacks subject matter jurisdiction to review state court decisions under the Rooker-Feldman doctrine.
- Defendant Drozd, a federal magistrate judge, is alleged to have violated the plaintiff’s civil rights, but is immune from damages for acts within jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the federal court has jurisdiction under Rooker-Feldman. | Todd contends federal review of state custody orders is permissible. | The district court has no jurisdiction to review state court judgments and the claims are inextricably intertwined with those judgments. | Lack of subject matter jurisdiction; claims dismissed under Rooker-Feldman. |
| Whether Drozd is immune from suit for judicial acts. | Drozd violated Todd’s civil rights in connection with findings and recommendations. | Judges are immune from damages for judicial acts within jurisdiction. | Drozd is immune; claim against him dismissed. |
Key Cases Cited
- Feldman v. District of Columbia, 460 U.S. 462 (1983) (federal review of state-court judgments is barred)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) (no federal jurisdiction to review state court judgments)
- Samuel v. Michaud, 980 F. Supp. 1381 (D. Idaho 1996) (unreviewable state-rule applications; jurisdictional limits)
- Branson v. Nott, 62 F.3d 287 (9th Cir. 1995) (no subject matter jurisdiction over certain §1983 state-court challenges)
- MacKay v. Pfeil, 827 F.2d 540 (9th Cir. 1987) (attacking state court judgment; Rooker-Feldman applies)
- Neitzke v. Williams, 490 U.S. 319 (1989) (frivolousness standard under §1915)
- Ashcroft v. Iqbal, 129 S. Ct. 1937 (2009) (facial plausibility required for claims)
- Twombly, 550 U.S. 544 (2007) (fact-specific pleading standard; avoid bare recitals)
- Mireles v. Waco, 502 U.S. 9 (1991) (judicial immunity; exceptions for clear absence of jurisdiction)
- Ashelman v. Pope, 793 F.2d 1072 (9th Cir. 1986) (judicial immunity analysis)