Rebekka Anne Behr v. James Campbell
8 F.4th 1206
11th Cir.2021Background
- Louis Behr lost custody of two children after Florida state child-custody proceedings; he and two other children (Rebekka and J.B.) alleged a conspiracy by multiple defendants to deprive him of custody.
- The Behrs filed pro se federal claims (after removal by two defendants) in a second amended complaint spanning 75 pages and 30 counts alleging federal constitutional violations (Fourth and Fourteenth Amendments), discrimination, fabrication of reports, coerced statements, unlawful entry, and various state-law claims.
- Seven days after filing the amended complaint, the district court sua sponte dismissed the entire complaint with prejudice for lack of subject-matter jurisdiction, invoking the Rooker–Feldman doctrine as precluding review of matters presented to the state court.
- The Eleventh Circuit reviews Rooker–Feldman jurisdictional rulings de novo and applies the Supreme Court’s narrowing of the doctrine in Exxon Mobil.
- The panel emphasized that Rooker–Feldman is narrow: it bars only federal-court suits by state-court losers that seek review and rejection of state-court judgments, not collateral claims for damages arising from state-court proceedings.
- The Eleventh Circuit vacated the district court’s wholesale Rooker–Feldman dismissal, holding that several federal claims (procedural due process, discrimination, and Fourth Amendment search) did not seek to overturn the state custody judgment and therefore survive Rooker–Feldman review; other dismissal grounds left to the district court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court properly dismissed the entire complaint under Rooker–Feldman | Behr: individual federal claims seek damages for constitutional violations arising from state proceedings or related conduct, not reversal of the state judgment | Defs: the federal claims are "inextricably intertwined" with and effectively seek review/rejection of the state custody judgment | Reversed in part: wholesale dismissal was error; Rooker–Feldman is narrow and dismissal must be claim-specific |
| Procedural due process (Count 2) | Behr: due-process violations (use of falsified/coerced info; denial of counsel) injured them and warrant damages | Defs: resolving the claim would require reviewing whether the state court’s custody decision was proper | Held: Claim seeks damages for constitutional violations, not undoing the custody judgment; Rooker–Feldman does not bar it |
| Discrimination (Count 10) | Behr: defendants discriminated by citing age, gender, religion, and disability during proceedings; relief is damages for discrimination | Defs: adjudication would force federal review of whether state court properly considered age and related factors in custody decision | Held: Claim challenges misconduct during state processes and seeks damages, not state-judgment reversal; Rooker–Feldman does not bar it |
| Fourth Amendment unreasonable search/seizure (Count 3) | Behr: investigators entered Louis’s home without permission/under false pretenses and seek damages | Defs: (implicit) connection to state proceedings makes the claim intertwined with the custody judgment | Held: Claim is independent (no request to overturn state judgment) and survives Rooker–Feldman |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (reaffirmed Rooker–Feldman is narrow and limited to appeals of state-court judgments)
- Rooker v. Fid. Tr. Co., 263 U.S. 413 (1923) (originally established that lower federal courts cannot reverse state-court judgments)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (1983) (held lower federal courts lack jurisdiction to review certain state-court decisions)
- Nicholson v. Shafe, 558 F.3d 1266 (11th Cir. 2009) (Eleventh Circuit applying Exxon Mobil to narrow Rooker–Feldman scope)
- Goodman ex rel. Goodman v. Sipos, 259 F.3d 1327 (11th Cir. 2001) (pre-Exxon case applying a broader Rooker–Feldman analysis; distinguished by the panel)
- VanderKodde v. Mary Jane M. Elliott, P.C., 951 F.3d 397 (6th Cir. 2020) (court must consider the relief sought when deciding if an injury arises from the state-court judgment)
- Lance v. Dennis, 546 U.S. 459 (2006) (Rooker–Feldman is distinct from claim-preclusion doctrines)