Robert Davis v. Ruth Johnson, 664 F. App'x 446

Background

Robert Davis sued multiple state actors, including Wayne County Circuit Judge Robert J. Colombo, Jr., under 42 U.S.C. § 1983 alleging First Amendment retaliation and Fourteenth Amendment due-process violations based on several election‑related state-court orders.
The district court dismissed claims against Judge Colombo on Rooker‑Feldman and judicial‑immunity grounds, dismissed a co‑plaintiff, and stayed other proceedings pending an administrative state remedy under Michigan law.
Davis sought emergency expedition of his appeal and asked the Sixth Circuit to prohibit Judge Colombo from presiding over a planned quo warranto action Davis intended to file challenging alleged election fraud tied to prior state orders.
The Sixth Circuit reviewed de novo whether Rooker‑Feldman deprived federal courts of subject‑matter jurisdiction and examined whether § 1983 (post‑1996 amendment) bars injunctive relief against a judicial officer in official capacity.
The panel concluded Davis’s injuries flowed from adverse state‑court orders and that his federal claims are barred by Rooker‑Feldman or, for prospective relief against a judge, by § 1983 limits; the court dismissed the appeal for lack of subject‑matter jurisdiction and remanded with instructions to dismiss pending claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rooker‑Feldman bars federal review of Davis’s claims attacking state‑court orders	Davis contends his federal rights were violated by state actors and seeks relief in federal court	Defendants assert Davis’s injury is caused by state‑court judgments, so Rooker‑Feldman precludes federal jurisdiction	Court: Rooker‑Feldman applies; federal courts lack subject‑matter jurisdiction because the alleged injury stems from state‑court orders
Whether Davis may obtain prospective relief (removal of Judge Colombo from future quo warranto case) in federal court	Davis asks the federal court to prohibit Judge Colombo from presiding over the planned quo warranto action	Defendants assert § 1983 (as amended) forbids injunctive relief against judicial officers in their official capacities and state remedies exist	Court: Relief against a judicial officer in official capacity is barred by § 1983 limits; state courts are the proper forum
Whether Davis’s claims include independent federal causes of action outside Rooker‑Feldman	Davis argues some claims (e.g., assignment‑rule challenge) are not based on a final state judgment and thus are independent	Defendants argue the claims are inextricably tied to state rulings and lack independence	Court: Complaint fails to allege independent federal claims that would avoid Rooker‑Feldman
Whether the Sixth Circuit should sua sponte dismiss for lack of jurisdiction without prior show‑cause to appellant	Davis (through concurrence view) sought opportunity to respond to jurisdictional concerns	The majority treated jurisdictional defect as amenable to sua sponte dismissal	Court: Majority dismissed appeal for lack of jurisdiction; concurrence would have issued show‑cause and allowed response

Key Cases Cited

McCormick v. Braverman, 451 F.3d 382 (6th Cir.) (Rooker‑Feldman standards and source‑of‑injury inquiry)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Supreme Court) (distinguishing federal review of state court judgments)
Executive Arts Studio, Inc. v. City of Grand Rapids, 391 F.3d 783 (6th Cir.) (when federal claim is inextricably intertwined with a state judgment)
Scottsdale Ins. Co. v. Flowers, 513 F.3d 546 (6th Cir.) (discretionary nature of declaratory relief and federal‑state comity concerns)
Chambers v. NASCO, Inc., 501 U.S. 32 (Supreme Court) (courts’ inherent authority to sanction vexatious or bad‑faith litigation)
Griggs v. Provident Consumer Discount Co., 459 U.S. 56 (Supreme Court) (effect of notice of appeal divesting district court jurisdiction)
Kontrick v. Ryan, 540 U.S. 443 (Supreme Court) (court may raise subject‑matter jurisdiction sua sponte)
Mansfield, C. & L.M.R. Co. v. Swan, 111 U.S. 379 (Supreme Court) (jurisdictional challenges may be raised at any stage of proceedings)