Sanford v. Hurst
5:24-cv-01406
N.D. Ala.May 20, 2025Background
- Alonzo Sanford, Jr., proceeding pro se, filed a federal lawsuit against Sarah Hurst, Director of Region 4 IV-D Agency, alleging violations of various constitutional rights in connection with the collection of child support under Title IV-D of the Social Security Act.
- Plaintiff's claims included alleged violations of his First, Fourth, Fifth, Seventh, and Thirteenth Amendment rights, as well as Monell liability, collusion, separation of powers violations, and dissemination of false advertisements.
- The case was originally before Magistrate Judge Johnson, who ordered Sanford to show cause why his complaint should not be dismissed for lack of federal subject matter jurisdiction.
- Sanford argued his claims arose from administrative or contractual actions by IV-D agencies, not from a state court order.
- The district court, sua sponte, determined that federal subject matter jurisdiction was lacking because all of plaintiff’s claims in essence challenged a state-court child support judgment.
- The court found the Rooker-Feldman doctrine barred the claims and, if state proceedings were ongoing, the domestic relations exception to federal jurisdiction would apply.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal Subject Matter Jurisdiction | Claims are against IV-D agency's administrative actions, not a state court judgment | Not directly stated | No jurisdiction; claims challenge state judgment |
| Constitutional Rights Violations (Multiple) | Various amendments violated via IV-D child support procedures and enforcement | Not directly stated | Claims dismissed for lack of jurisdiction |
| Rooker-Feldman Application | Doctrine does not apply because challenge is to administrative agency, not court order | Not directly stated | Doctrine applies; federal review barred |
| Domestic Relations Exception | Case does not implicate domestic relations issues | Not directly stated | Exception would bar claim if state case ongoing |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of America, 511 U.S. 375 (federal courts are of limited jurisdiction)
- Smith v. GTE Corp., 236 F.3d 1292 (federal court must ensure jurisdiction exists)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (federal courts cannot review state-court judgments)
- District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (federal courts lack power to review state-court decisions)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (scope and standard for Rooker-Feldman)
- Ankenbrandt v. Richards, 504 U.S. 689 (domestic relations exception to federal jurisdiction)