68 F.4th 336
6th Cir.2023Background
- Hohenberg and Hanson owned Memphis homes that fell into disrepair; neighbors and the State brought code-enforcement actions in the Shelby County Environmental Court.
- Environmental Court proceedings led to receivership and sale of Hohenberg’s house, contempt and jail for Hanson, and demolition of Hanson’s house; both enforcement actions later became moot.
- Plaintiffs sued the Environmental Court and Shelby County under 42 U.S.C. § 1983 alleging Fourteenth Amendment due-process violations based on the Court’s procedures, lost case files, and the County’s creation/funding/oversight failures.
- The district court dismissed the case: finding lack of jurisdiction under 28 U.S.C. § 1257(a) (Rooker–Feldman) for most claims and holding that the Environmental Court cannot be sued under § 1983; it also dismissed some County-related claims for failure to state a claim.
- The Sixth Circuit reversed the jurisdictional dismissal (Rooker–Feldman inapplicable to most claims), affirmed that the Environmental Court is an arm of the State and not a § 1983 “person,” and remanded unresolved Monell/County issues for further consideration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 1257(a) (Rooker–Feldman) bars federal jurisdiction | Hohenberg/Hanson: claims seek damages/declaratory relief for procedural harms, not review of state judgments | County/Court: federal suit impermissibly seeks to undo state-court judgments | §1257(a) does not bar these claims—Rooker–Feldman applies only when a plaintiff seeks to review/reject a specific state-court judgment; reversed jurisdictional dismissal |
| Whether damages or declaratory relief would impermissibly review state judgments | Plaintiffs: damages and a system-wide declaratory remedy do not seek to overturn specific state orders | Defendants: relief would undermine the Environmental Court’s orders and function as an appeal | Damages and a declaratory judgment here do not necessarily seek review/rejection of particular state judgments; Rooker–Feldman inapplicable |
| Whether the Environmental Court is a “person” under § 1983 | Plaintiffs: Court is effectively a county entity and thus subject to § 1983 | Defendants: Environmental Court is an arm of the State and not a § 1983 person | Environmental Court is an arm of Tennessee, not a § 1983 “person”; claim against the Court fails |
| Whether County § 1983 (Monell) claims were plausibly pleaded | Plaintiffs: County created, funded, and failed to oversee the Court, causing constitutional violations | County: no policy or custom caused plaintiffs’ injuries; merits not sufficiently pleaded | Sixth Circuit declined to resolve merits; remanded for district court to address Monell causation/pleading issues |
Key Cases Cited
- Rooker v. Fid. Trust Co., 263 U.S. 413 (U.S. 1923) (only the Supreme Court may review final state-court judgments)
- Dist. of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (applies Rooker principle to state-court decisions on federal questions)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (narrows Rooker–Feldman: requires a prior judgment and a request to review/undo it)
- Will v. Michigan Dep’t of State Police, 491 U.S. 58 (U.S. 1989) (States and state agencies are not “persons” under § 1983)
- Monell v. N.Y. City Dep’t of Soc. Servs., 436 U.S. 658 (U.S. 1978) (municipal liability under § 1983 requires an offending policy or custom causing the violation)
- Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (due-process inquiry uses a balancing test focused on procedural fairness)
- VanderKodde v. Mary Jane M. Elliott, P.C., 951 F.3d 397 (6th Cir. 2020) (distinguishing delay/lost-files injuries from errors in a court’s adjudication for Rooker–Feldman purposes)